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PEOPLE v. ESTANLY OCTA Y BAS

FACTS:

The case involves accused-appellant Estanly Octa y Bas, who filed a Notice of Appeal after his conviction for kidnapping for ransom was affirmed by the Court of Appeals (CA). According to the prosecution, on September 25, 2003, Johnny Corpuz and Mike Adrian Batuigas were in a car when they were attacked by armed men from another car. The armed men shot at the car window, forcibly entered, and kidnapped Johnny. The kidnappers later contacted Johnny's wife, demanding a ransom for his release. After negotiations, a ransom amount was agreed upon, and Johnny's wife handed the money to a man wearing a red cap, identified as accused-appellant Estanly Octa. Eventually, Johnny was released upon payment of the ransom.

On the other hand, the defense presented a different version of events. They claimed that accused-appellant was in a different location during the incident and was actually a victim of abduction. Despite this, accused-appellant was arrested and charged with kidnapping for ransom. Eventually, he was found guilty by the Regional Trial Court, which imposed the maximum prison term of reclusion perpetua and ordered him to pay damages.

ISSUES:

  1. Did the trial court err in convicting the accused despite the prosecution's failure to positively identify him as the ransom taker?

  2. Did the trial court err in finding the accused to be a conspirator to the crime charged?

  3. Did the trial court err in convicting the accused based on circumstantial evidence?

  4. Whether the failure of the witness to mention in her initial statement that the ransom taker had a dimple is fatal to her testimony and identification.

  5. Whether accused-appellant can be considered a conspirator in the crime of kidnapping for ransom based on his receipt of the ransom money.

RULING:

  1. The Court denied the accused-appellant's appeal.

  2. The failure of the witness to mention in her initial statement that the ransom taker had a dimple is not fatal to her testimony and identification. The positive and categorical identification of the accused-appellant by the witness during the police line-up and in open court cured any initial flaw in the out-of-court identification. The inadmissibility of a police line-up identification does not foreclose the admissibility of an independent in-court identification.

  3. Accused-appellant can be considered a conspirator in the crime of kidnapping for ransom based on his receipt of the ransom money. Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. The acts of the accused-appellant, together with the other accused, demonstrate a common design or purpose to commit the felony of kidnapping for ransom. Therefore, accused-appellant's argument that he is a mere accomplice must fail.

PRINCIPLES:

  • When the credibility of a witness is at issue, the findings of fact of the trial court are accorded high respect and conclusive effect, especially if affirmed by the appellate court.

  • The assessment of the credibility of witnesses, their demeanor, and the probative weight of their testimonies are best performed by the trial court, which can observe the witnesses firsthand.

  • Positive identification, when categorical, consistent, and without any showing of ill motive, prevails over mere alibi and denial. It constitutes direct evidence.

  • When a crime is still ongoing, an accused's act of taking ransom money can be evidence of his complicity in the crime.

  • The inadmissibility of a police line-up identification does not foreclose the admissibility of an independent in-court identification.

  • Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it.

  • To hold an accused guilty as a co-principal by reason of conspiracy, he must be shown to have performed an overt act in pursuance or furtherance of the complicity.

  • The receipt of ransom money can be considered a conspiratorial act in the commission of kidnapping for ransom.

  • The positive identification of the accused constitutes direct evidence, and not merely circumstantial evidence.