By Benjamin Cuaresma
MANILA — The Supreme Court (SC) has ruled that the loss or non-presentation of ransom money in court does not automatically weaken a kidnapping-for-ransom case, as long as prosecutors can prove that a ransom demand was made for the victim’s release.
In a decision penned by Associate Justice Ricardo R. Rosario, the High Court’s First Division upheld the conviction of Jose Olbato, Police Officer III Clayton Patingan, and their co-accused for kidnapping for ransom.
Court records showed that the group forcibly abducted Genevieve Ong Sy while she was driving one morning and detained her inside a safe house. The kidnappers initially demanded P50 million from Sy’s father in exchange for her freedom before eventually lowering the amount to P500,000 after negotiations.
Under a police-monitored operation, the victim’s family driver delivered marked ransom money to the suspects, prompting law enforcers to rescue Sy, arrest the accused, and recover the marked cash.
Both the Regional Trial Court and the Court of Appeals found the accused guilty, rejecting their defenses of denial and alibi.
Before the Supreme Court, however, the accused argued that prosecutors failed to establish their guilt beyond reasonable doubt because the ransom money was never presented during trial after it was reportedly lost while under police custody.
The High Court rejected the argument, explaining that the essence of kidnapping for ransom lies in the unlawful deprivation of a person’s liberty for the purpose of extorting ransom—not in the physical presentation of the ransom money as evidence.
The SC stressed that the crime is already consummated once the prosecution proves that the victim was illegally detained and that a ransom was demanded for the victim’s release.
In this case, the Court found overwhelming evidence that the kidnappers repeatedly demanded money from the victim’s father, negotiated the amount, and ultimately received the ransom during the police operation.
According to the Court, the subsequent loss of the marked money while in police custody did not erase the fact that the ransom demand had been made and carried out.
The High Tribunal also clarified that although Patingan was an active police officer when the incident occurred, he was treated as a private individual under the law because he was not acting in the performance of his official duties when he participated in the kidnapping.
The Supreme Court affirmed the sentence of reclusion perpetua, carrying imprisonment of up to 40 years, against all the accused. They were likewise ordered to jointly pay the victim P300,000 in civil indemnity and damages.
The ruling reinforces the long-standing principle that in kidnapping-for-ransom cases, the prosecution’s burden is to establish the unlawful detention and the ransom demand, not the continued existence or courtroom presentation of the ransom money itself.
ia/xf
