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PEOPLE v. BENEDICTO RAMOS Y BINUYA

FACTS:

On July 13, 1994, an American pastor named Malcolm Bradshaw witnessed Alicia Abanilla being held against her will by Benedicto Ramos. Bradshaw stopped his car to help Abanilla, but Ramos managed to squeeze himself into Bradshaw's car. Ramos then forced Bradshaw to drive to a specific location in Quezon City. During the drive, Abanilla asked Ramos about the well-being of a certain person named Cecil, but Ramos did not answer. Upon reaching their destination, Ramos forced Abanilla out of the car. Bradshaw later found a receipt dropped by Abanilla which contained her name and residence telephone number. He called the number and learned that Abanilla was being held hostage for ransom. Abanilla also called her boss, Atty. Pastor del Rosario, asking for P200,000 in cash and instructing him to give the money to a messenger at Meralco. Del Rosario complied and the messenger was supposed to deliver the money to Abanilla at a supermarket in Sikatuna Village.

However, the messenger refused to give the money to Abanilla, prompting Abanilla to give her identification card to a taxi driver and ask him to show it to the messenger. Upon recognizing Abanilla, the messenger handed the money to the taxi driver, and Ramos instructed the driver to head to Norzagaray. However, Ramos changed his mind and decided to go to Bocaue, Bulacan.

ISSUES:

  1. Whether the accused-appellant Benedicto Ramos y Binuya alias "Bennie" is guilty beyond reasonable doubt of kidnapping for ransom.

  2. Whether the accused-appellant Benedicto Ramos y Binuya is guilty beyond reasonable doubt of murder.

  3. Whether the crimes of kidnapping for ransom and murder should be treated as separate crimes or as a special complex crime.

RULING:

  1. Kidnapping for Ransom: Yes, the Supreme Court found accused-appellant Benedicto Ramos guilty beyond reasonable doubt of kidnapping for ransom. The Court held that the actual deprivation of the victim's liberty was evident from the moment she was forcibly prevented from going to Meralco and taken instead against her will to Bulacan, where her freedom of movement was effectively restricted by the appellant who was armed with a revolver.

  2. Murder: Yes, the Supreme Court found accused-appellant Benedicto Ramos guilty beyond reasonable doubt of murder. The Court ruled that Ramos exhibited deliberate intent to kill the victim, Alicia Abanilla, as evidenced by shooting her twice in the head while she was attempting to escape, making the crime qualified by treachery.

  3. Special Complex Crime: The Supreme Court ruled that the crimes of kidnapping for ransom and murder should not be treated as separate crimes but as a special complex crime under Art. 267 of The Revised Penal Code, as amended by RA No. 7659. Even though the kidnapping for ransom was consummated with the demand for ransom, the detention persisted until the victim was killed, making her death a consequence of the kidnapping.

PRINCIPLES:

  1. Actual Deprivation of Liberty: Actual deprivation of liberty for kidnapping can include not just incarceration but also any form of detaining a person or restricting their freedom of movement.

  2. Special Complex Crime: Under the amended Art. 267 of The Revised Penal Code by RA No. 7659, the killing of a kidnapped victim constitutes a special complex crime of kidnapping for ransom with murder or homicide, eliminated the distinction between premeditated murder and afterthought killing during detention.

  3. Imposition of Death Penalty: When a victim is killed as a consequence of kidnapping, the maximum penalty of death should be imposed upon the accused under the current legal framework, subject to the President's power to pardon upon finality of the decision.

  4. Credibility of Witnesses: Minor inconsistencies in witnesses' testimonies generally do not affect their credibility as long as the essential facts leading to the guilt of the accused are coherent and consistent.

  5. Demand for Ransom: The demand for ransom in kidnapping cases can be made directly upon the victim and does not need to be addressed to relatives or friends to constitute the crime of kidnapping for ransom.

  6. Positive Identification: Positive identification by credible witnesses, supported by testimonial and material evidence, is fundamental in establishing the guilt of the accused beyond reasonable doubt.

  7. Rule on Evidence and Defenses: Bare denials and implausible defense narratives are insufficient to counter positive, credible, and consistent prosecution evidence.