FACTS:

The appellants, Ireneo Fajardo and Ruperto Fajardo, were charged and convicted for the crimes of kidnapping for ransom and serious illegal detention. The trial court found them guilty and sentenced them to reclusion perpetua. The other accused in the case remained at large, except for Simplicio Atienza who was acquitted. The trial court concluded that the kidnapping incident occurred when the executives of Mitsui & Co. and other Japanese companies were playing golf at the Canlubang Golf Club. The convoy of executives was overtaken by two cars, and Nobuyuki Wakaoji was forcibly taken by two men and shoved into a blue Toyota Cressida. Testimonies from witnesses Mario Palig and Jimmy Lasam supported the finding of "detention." The trial court also found that the victim was moved from one location to another to evade the authorities. The appellants appealed the decision, raising several errors in their defense. However, the Court found the appeal to be without merit.

ISSUES:

1. Whether the prosecution witnesses were procured, perjured, or rehearsed.

2. Whether the trial court erred in considering statements which were inadmissible in evidence.

3. Whether the positive identification of the appellants was established.

4. Whether the trial court erred in determining Ireneo Fajardo’s actual participation in the crime.

5. Whether the trial court erred in finding Ireneo Fajardo as the most “prominent among” the conspirators.

6. Whether the distance between the witness and the accused affects the credibility of the identification.

7. Whether the defense of alibi can prevail in this case.

8. Whether or not negative and self-serving evidence should be given weight in law.

9. Whether or not newspaper reports containing "confessions" of different persons are considered newly discovered evidence.

10. Whether or not the guilt of the appellants has been established beyond reasonable doubt.

11. Whether or not the elements of serious illegal detention have been proven.

RULING:

1. The appellants failed to substantiate their claim that the prosecution witnesses were procured, perjured, or rehearsed, and thus their testimonies shall be entitled to full faith and credit.

2. Even if the trial court erroneously considered statements that were inadmissible in evidence, the convictions should still be sustained based on other admissible evidence, such as the testimonies of the prosecution witnesses.

3. The appellants were positively identified by the prosecution witnesses, and the court found their identification to be credible.

4. Although there may have been an error in determining Ireneo Fajardo’s actual participation in the crime, his presence during the abduction and kidnapping was sufficiently established by a prosecution witness.

5. The trial court erred in finding Ireneo Fajardo as the most “prominent among” the conspirators, but records show that he was present and actively involved in the crime.

6. The distance between the witness and the accused does not affect the credibility of the identification, especially when the witness had gained familiarity with the accused prior to the crime.

7. The defense of alibi cannot prevail over positive identification, as it is the weakest defense and requires clear and convincing evidence to be substantiated.

8. Negative and self-serving evidence are considered undeserving of weight in law.

9. Newspaper reports containing "confessions" of different persons are not considered newly discovered evidence and are incompetent and inadmissible for being hearsay.

10. The guilt of the appellants has been established beyond reasonable doubt.

11. The elements of serious illegal detention have been proven.

PRINCIPLES:

• Mere allegations are not equivalent to proof, and each party must prove their affirmative allegations.

• Testimonies that are categorically, spontaneously, frankly, and consistently given are considered credible.

• The fact that a witness did not personally know the accused does not prevent positive identification.

• Conditions of visibility and lack of bias of the witness contribute to the acceptance of the witness' identification of the accused.

• Alibi is the weakest defense and cannot prevail over positive identification. Clear and convincing evidence is required to substantiate an alibi defense.

• Negative and self-serving evidence are undeserving of weight in law.

• Newspaper reports containing "confessions" of different persons are considered hearsay and are incompetent and inadmissible as evidence.

• The guilt of the accused must be proven beyond reasonable doubt.

• The elements of serious illegal detention are: (a) the offender is a private individual; (b) he kidnaps or detains another, or in any other manner deprives the latter of his liberty; (c) the act of detention or kidnapping must be illegal; and (d) any of the following circumstances are present: (i) the kidnapping or detention lasts for more than 5 days; (ii) it is committed simulating public authority; (iii) any serious physical injuries are inflicted upon the person kidnapped or detained or threats to kill him are made; or (iv) the person kidnapped is a minor, female, or public officer.