People vs. Galicia, 990 SCRA 190, June 28, 2021
Uploaded by
Rizchelle Sampang-ManaogPeople vs. Galicia, 990 SCRA 190, June 28, 2021
Uploaded by
Rizchelle Sampang-ManaogPeople vs.
Galicia, 990 SCRA 190, June 28, 2021
Topic: Credibility of Witnesses
Facts: The victim, Venilda Marcelo Ho (Venilda), was engaged in a dress and
gown making business. On May 8, 2003, she was at her shop located in
Timog Avenue, Quezon City. At around 7:00 p.m., she decided to go home
and was kidnapped by four men (later identified as Galicia, Chiva, Villarino,
and Ugat, Jr.).
The kidnappers were able to talk to Venilda’s husband, William Ho (William)
through an alias Kumander Abdul who negotiated for them. During the
negotiations, the kidnappers demanded P50,000,000.00 as ransom money
but was later reduced to P500,000.00. Kumander Abdul threatened William
that they will harm Venilda if they fail to produce the ransom money.
Kumander Abdul called William and asked him how much money he was able
to raise. William replied that he had only P224,500.00. Kumander Abdul
ordered him to go to Batangas City for the payoff. At around 10:00 p.m.,
William left for Batangas. Unknown to Kumander Abdul and his cohorts,
William already reported the kidnapping to the police.
Kumander Abdul further demanded the amount of P5,000,000.00 ransom
money. William made a counteroffer of P225,000.00, but Kumander Abdul
rejected it. He warned William that he would cut off one of the fingers of his
wife if he failed to produce the amount demanded. On May 22, 2003,
Kumander Abdul called William and informed him that they agreed to a
reduced ransom money in the amount of P250,000.00. Thus, at around 2:00
p.m., the PACER agents saw Galicia and Portugal board the Mitsubishi
Adventure that was used during the payoff.
On May 23, 2003, at around 6:00 a.m., P/Supt. Gohel informed Police
Inspector Christian Dela Cruz (P/Insp. Dela Cruz), the chief for follow-up
operations, that there would be a second payoff at Nayong Filipino.
After confirming the identity of the man at the shed as the suspect, the
police officers approached him. The man immediately ran away. But
eventually, the police officers arrested him, and he was later identified as
Chiva.
The police officers then went to a shanty in Nayong Filipino to verify the
identity of another suspect. A male person noticed them and scampered
away. The police
officers arrested the male person, who was later identified as Villarino.
During the operation, the police officers also noticed a red Kia Sedan inside
the Nayong Filipino. The team inspected the vehicle and identified
themselves as police officers to the men inside. A passenger stepped out and
introduced himself as one Major Ugat, Jr., a police officer. Right then and
there, the police officers arrested him and informed him of his rights.
RTC rendered a Decision finding accused-appellants and Ugat, Jr. as
principals; and Billones as an accomplice, guilty beyond reasonable doubt of
the crime of Kidnapping for Ransom. CA rendered the assailed Decision
denying the appeal. It agreed with the RTC that all the elements of the crime
of Kidnapping with Ransom were proven by the prosecution. It likewise gave
more weight to Venilda’s testimony and positive identification of the
kidnappers. Further, the CA affirmed the RTC’s findings of the existence of
conspiracy between accused-appellants and Ugat, Jr. Furthermore, the CA
upheld the RTC’s ruling that accused Billones is merely an accomplice in the
commission of the crime.
Issue: Whether or not the CA erred in affirming accused-appellants’
conviction for Kidnapping with Ransom.
Ruling: The appeal has no merit.
The Court finds no reason to deviate from the uniform factual findings of the
RTC and the CA as there is no indication that they overlooked,
misunderstood, or misapplied the surrounding facts and circumstances of the
case. It is settled that findings of the trial court which are factual in nature
and which involve the credibility of witnesses are accorded with respect, if
not finality by the appellate court, when no glaring errors, gross
misapprehension of facts, and speculative, arbitrary, and unsupported
conclusions can be gathered from such findings.
Moreover, the prosecution was able to establish beyond reasonable doubt
the conspiracy between accused- appellants and their co-accused Ugat, Jr.
The RPC provides that a conspiracy exists when two or more persons come
to an agreement concerning the commission of a felony and decided to
commit it.
The inherently weak defenses of denial and alibi of accused-appellants
cannot be accorded greater evidentiary weight than the identification made
by the credible prosecution witnesses.
Appeal is dismissed.
Doctrine: The Court finds no reason to deviate from the uniform factual
findings of the RTC and the CA as there is no indication that they overlooked,
misunderstood, or misapplied the surrounding facts and circumstances of the
case. It is settled that findings of the trial court which are factual in nature
and which involve the credibility of witnesses are accorded with respect, if
not finality by the appellate court, when no glaring errors, gross
misapprehension of facts, and speculative, arbitrary, and unsupported
conclusions can be gathered from such findings.
