FACTS:

Sgt. Wennie Tampioc, together with three members of the local Citizen Armed Force Geographical Unit (CAFGU) were charged with Kidnapping and Serious Illegal Detention. The victim, Samson Sayam, was last seen drinking beer with the accused at a store. Later that night, all the accused and the victim left the store and walked towards the direction of the military detachment headquarters. Witnesses heard a gunshot followed by rapid firing from that direction. Samson Sayam has not been seen since. The trial court held that the prosecution failed to prove a conspiracy but found three accused responsible for the victim's disappearance. Sgt. Wennie Tampioc was found not liable due to doubt regarding his identity. The trial court sentenced the three accused to Reclusion Perpetua and ordered them to pay damages to the victim.

The accused-appellants were charged with Kidnapping and Serious Illegal Detention. Witnesses testified that the accused-appellants, who were members of CAFGU, were seen with the victim, Samson Sayam, heading towards the CAFGU detachment headquarters. It was alleged that the victim was brought to the detachment headquarters and was never seen or heard from again. The trial court convicted the accused-appellants, but they filed separate appeals asserting their innocence due to insufficient evidence. The Solicitor General conceded that the accused-appellants should not have been charged and convicted of Kidnapping and Serious Illegal Detention but argued they should be liable for Arbitrary Detention instead. The issue before the Supreme Court was whether the evidence proved that the accused-appellants arbitrarily detained the victim.

Carlito Manlangit, father of the accused-appellant Jerry Manlangit, testified in the case to establish certain facts.

ISSUES:

1. Whether there is sufficient evidence to prove that Samson Sayam was detained and deprived of his liberty

2. Whether the testimonies presented by the prosecution establish the elements of arbitrary detention

3. Whether the prosecution presented sufficient evidence to establish the guilt of the accused-appellants for arbitrary detention

4. Whether the circumstances presented by the prosecution were consistent with the hypothesis of the guilt of the accused-appellants

5. Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the accused-appellants.

6. Whether the prosecution was able to establish the guilt of the accused-appellants beyond reasonable doubt.

RULING:

1. The evidence presented by the prosecution failed to prove that Samson Sayam was detained and deprived of his liberty. There was no uncontroverted proof of both intent to deprive the victim of his liberty and actual confinement or restriction.

2. The testimonies presented by the prosecution did not establish the elements of arbitrary detention. The witnesses did not provide sufficient evidence to show that Sayam was forcibly taken to the detachment headquarters or that he was protesting his apprehension.

3. The Supreme Court found that the prosecution failed to present sufficient evidence to establish the guilt of the accused-appellants for arbitrary detention. The testimonial evidence of the prosecution witness lacked credibility, as he wavered on material points and was not corroborated by direct or corroborative evidence. The Court emphasized that in criminal prosecutions, the guilt of the accused must be proven beyond reasonable doubt. The factual findings of the trial court may be reversed if there are substantial facts that were overlooked which may alter the results of the case in favor of the accused. After a thorough review of the evidence, the Court concluded that the evidence of the prosecution was grossly insufficient to sustain a conviction.

4. The Court held that the prosecution failed to prove the guilt of the accused-appellants beyond reasonable doubt. Although the circumstantial evidence presented showed that the accused-appellants were the last persons seen with the victim, this circumstance alone does not prove that they feloniously abducted and arbitrarily detained him. Mere suspicion and uncorroborated circumstantial evidence are insufficient to convict the accused. The prosecution did not present an unbroken chain of circumstances leading to the conclusion that the accused-appellants are guilty. Therefore, the Court acquitted the accused-appellants.

PRINCIPLES:

• Detention is defined as the actual confinement or restriction of a person's liberty.

• To establish arbitrary detention, there must be uncontroverted proof of both intent to deprive the victim of his liberty and actual confinement or restriction.

• Hearsay evidence has no probative value.

• In criminal prosecutions, guilt must be proven beyond reasonable doubt.

• Factual findings of the trial court may be reversed if there are substantial facts that were overlooked which may alter the results of the case in favor of the accused.

• The evidence of the prosecution must be credible and substantiated by direct or corroborative evidence.

• Circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts from which the inferences are derived are proven, and the combination of all the circumstances produces a conviction beyond reasonable doubt.

• For circumstantial evidence to support a conviction, all the circumstances must be consistent with the hypothesis of the guilt of the accused, and inconsistent with the possibility that they are innocent.

• Circumstantial evidence must constitute an unbroken chain of events that can lead reasonably to the conclusion pointing to the accused, to the exclusion of all others, as the guilty person.

• The prosecution must establish its case with a degree of proof that leads to no other conclusion but conviction in an unprejudiced mind.

• The evidence for the prosecution must stand or fall on its own merits and cannot draw strength from the weakness of the evidence for the defense.

• It is better to acquit a guilty person than to convict an innocent one.