People vs. Ali, et. al (2017)

PEOPLE OF THE PHILIPPINES vs. USTADZ IBRAHIM ALI, ET. AL.

G.R. No. 222965, December 6, 2017 

MARTIRES, J.:

Facts: In an Information, Ali, together with other accused were charged with the crime of kidnapping and serious illegal detention alleging that accused being then armed with high powered firearm, conspiring with one another, by means of force and intimidation feloniously, KIDNAP the person of CHRISTIA OLIZ y EUCOGCO, a young woman, 19 years old, particularly on the occasion when she was together with her employer named Antonio Yu Lim Bo and the latter's wife and daughter, on board a Blue Nissan Vehicle then driven by one Rene Igno, and thereafter through intimidation, commandeered and drove said vehicle towards the area of Pitogo beach with the clear intention on the part of the accused to extort ransom money from said victim or other person.

Appellant claimed that before the alleged incident, Hassan pushed Ali inside the motor vehicle while he was holding a gun and told him to follow or he would be in trouble. When all occupants arrived at the beach and alighted therefrom, Ali decided to walk away and proceed to the main road to catch a ride. Ali argues that he could not be guilty of the crime of Serious Illegal Detention because the alleged deprivation of liberty did not last for more than three (3) days as the incident only lasted for about an hour or two

Issue: Whether or not appellant is guilty of serious illegal detention.

Ruling: Yes. Deprivation of liberty is qualified to serious illegal detention if, among others, the victim is a minor, female or public officer.

In the case at bar, the elements of serious illegal detention were duly proven by the prosecution. First, Ali and his cohorts were clearly private individuals. Second, they deprived Oliz of her liberty. This was manifested by the fact that they forcibly boarded the vehicle and placed Igno and Antonio in handcuffs. Third, Oliz was a female victim. In the case at bar, it is unquestionable that Ali was identified with moral certainty. Oliz was able to distinguish and identify accused considering their proximity inside the vehicle and the duration of the captivity.

Ratio Decidendi: The essence of serious illegal detention is the actual deprivation of the victim's liberty, coupled with the indubitable proof of intent of the accused to effect such deprivation-it is enough that the victim is restrained from going home.

Gist: This is an appeal from the Decision of the CA, which affirmed the Decision of the RTC, finding appellant of the crime of Kidnapping and Serious Illegal Detention.