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    People v. Estanly Octa

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    Erika Pineda
    Estanly Octa was convicted of kidnapping Johnny Corpuz and Mike Adrian Batuigas. [1] The victims were intercepted by armed men in a car and detained in a safe house for 6 days. [2] Ransom was demanded from Johnny's wife, and she paid 538,000 pesos to a man matching Estanly's description. [3] The Supreme Court affirmed the conviction, finding Estanly liable as a conspirator for receiving the ransom payment, even if it was not a material element of the crime, as it was part of the kidnapping plan.

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    People v. Estanly Octa

    Uploaded by

    Erika Pineda
    354 views2 pages
    Estanly Octa was convicted of kidnapping Johnny Corpuz and Mike Adrian Batuigas. [1] The victims were intercepted by armed men in a car and detained in a safe house for 6 days. [2] Ransom was demanded from Johnny's wife, and she paid 538,000 pesos to a man matching Estanly's description. [3] The Supreme Court affirmed the conviction, finding Estanly liable as a conspirator for receiving the ransom payment, even if it was not a material element of the crime, as it was part of the kidnapping plan.

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    6. People v. Estanly Octa

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    Estanly Octa was convicted of kidnapping Johnny Corpuz and Mike Adrian Batuigas. [1] The victims were intercepted by armed men in a car and detained in a safe house for 6 days. [2] Ransom was demanded from Johnny's wife, and she paid 538,000 pesos to a man matching Estanly's description. [3] The Supreme Court affirmed the conviction, finding Estanly liable as a conspirator for receiving the ransom payment, even if it was not a material element of the crime, as it was part of the kidnapping plan.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    354 views2 pages

    People v. Estanly Octa

    Uploaded by

    Erika Pineda
    Estanly Octa was convicted of kidnapping Johnny Corpuz and Mike Adrian Batuigas. [1] The victims were intercepted by armed men in a car and detained in a safe house for 6 days. [2] Ransom was demanded from Johnny's wife, and she paid 538,000 pesos to a man matching Estanly's description. [3] The Supreme Court affirmed the conviction, finding Estanly liable as a conspirator for receiving the ransom payment, even if it was not a material element of the crime, as it was part of the kidnapping plan.

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    © All Rights Reserved
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    of 2

    G.R. No.

    195196, July 13, 2015


    PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. ESTANLY OCTA Y BAS, Accused-
    Appellant.
    SERENO, C.J.:

    Crime Kidnapping

    Accused Estanly Octa


    Victim Johnny Corpuz (Johnny) and Mike
    Adrian Batuigas (Mike Adrian)
    Location Sampaloc, Manila

    RTC Decision Guilty as Charged, kidnapping

    CA Decision Affirmed in toto

    SC decision affirmed/Guilty as Charged, kidnapping

    FACTS:

    In the morning of September 25, 2003, around 6:40 A.M., Johnny Corpuz (Johnny) and
    Mike Adrian Batuigas (Mike Adrian) while on board a Honda Civic Car were intercepted in
    Sampaloc, Manila and their way blocked by a Mitsubishi box type Lancer car. Four (4) armed
    occupants of the Lancer car alighted and proceeded to commandeer the Honda Civic. Johnny was
    then compelled to move to the back of the car after which he was handcuffed. Johnny and Mike
    Adrian were brought to a safe house. Johnny’s wife Ana Marie Corpuz (Ana Marie) was contacted
    and the kidnappers demanded an amount of 20 million pesos as ransom but the amount was
    considerably reduced up to the time that Ana Marie was able to raise the amount of P538,000.00
    which was accepted by the kidnappers.

    Finally, on September 30, 2003 at 10 PM, the kidnappers set up the manner on how the
    ransom money would be delivered. Ana Marie was made to travel to several locations until she was
    directed to a Caltex Auto Supply where she would see a man wearing a red cap and who would ask
    her “saan yong padala ni boss”. She was instructed to deliver the wrapped bundled ransom money
    to the man wearing red cap. When she saw the man with red cap, she was asked for the money.

    She described the man wearing red cap to be goodlooking, lightly built, in his early 20s,
    around 5’4” in height and with dimples, which she later identified in court as accused Estanly Octa.

    Johnny was released by his captors after the payment of ransom money. He was detained
    for the duration of six (6) days. When he was released, his brother-in-law Mike Adrian was also
    released.

    The defense set up denial and alibi as defense.

    The accused was charged with kidnapping. The RTC rendered a Decision finding accused
    guilty as charged. CA affirmed in toto the RTC decision.
    Accused appealed the case contending that he should not be considered as conspirator to the
    kidnapping in the absence of concrete proof that he actually participated in the execution of the
    essential elements of the crime by overt acts indispensable to its accomplishment.

    ISSUE:
    Whether or not there was conspiracy.

    HELD:
    We deny accused-appellant’s appeal. On point is our dissertation in People v. Bautista:

    Conspiracy exists when two or more persons come to an agreement concerning the
    commission of a felony and decide to commit it. Where all the accused acted in concert at
    the time of the commission of the offense, and it is shown by such acts that they had the
    same purpose or common design and were united in its execution, conspiracy is sufficiently
    established. It must be shown that all participants performed specific acts with such
    closeness and coordination as to indicate a common purpose or design to commit the
    felony.

    xxxx

    Evidently, 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. There
    must be intentional participation in the transaction with a view to the furtherance of the
    common design and purpose. x x x.

    xxxx

    Taking these facts in conjunction with the testimony of Dexter, who testified that accused-
    appellant was the one who received the ransom money x x x then the commonality of
    purpose of the acts of accused-appellant together with the other accused can no longer be
    denied. Such acts have the common design or purpose to commit the felony of kidnapping
    for ransom.

    Thus, accused-appellants’ argument that he is a mere accomplice must fail. He is liable as a


    principal for being a co-conspirator in the crime of Kidnapping for Ransom under Art. 267
    of the RPC, as amended by R.A. 7659 x x x.32 (Emphasis ours)

    Moreover, the CA is correct in its observation that at the time accused-appellant received the
    ransom money, the crime of kidnapping was still continuing, since both victims were still being
    illegally detained by the kidnappers.33 While his receipt of the ransom money was not a material
    element of the crime, it was nevertheless part of the grand plan and was in fact the main reason for
    kidnapping the victims.34 Ransom is money, price or consideration paid or demanded for the
    redemption of a captured person or persons; or payment that releases from captivity.35 Without
    ransom money, the freedom of the detained victims cannot be achieved.

    WHEREFORE, the appeal is hereby DISMISSED. The assailed Decision of the Court of Appeals in
    CA-G.R. CR.-HC No. 03490 is AFFIRMED.

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