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Valenton, Francis Angelo T.

Criminal Law 2


People vs. Dadles (G.R. No. 118620-21)

Facts: The plaintiff-appellee is the People of the Philippines. The accused-appellant is Narito
Naring Dadles. In the case at bar, on May 24, 1989 the appellant Dadles together with five
others, namely Dindo, Mike, Willy, Morito, and Juanito arrived at the residence of one of the
victims in Barangay Amontay, Binalbagan, Negros Occidental. Alipio and his wife, Francisca,
and their two sons were awakened from their sleep when the appellant and his companions called
Alipio from downstairs. The group which was known to the Tehidor family because they used to
visit the latters house to ask for rice was allowed to enter by Francisca. Once inside, they told
Francisca that they wanted to talk to Alipio. Francisca asked them not to bring Alipio outside and
to just talk to him upstairs but her request went unheeded. Then Morito then assisted by the
appellant, tied the hands two sons. When Francisca protested, the appellants group told her that
they would free their sons if they surrender the firearms of their two other sons, Logenio and
Jenny, both of whom were members of the Civilian Armed Forces Geographical Units
(CAFGU). Unable to surrender the said firearms which were not in the possession of the spouses
Tehidor, the appellants group forced Alipio and Dionisio to walk with them to an unknown
place. Since then and up to the present, Francisca has not heard from either her husband or her
son. The Regional Trial Court rendered a decision convicting the appellant of two counts of
kidnapping and serious illegal detention.

Issue: Is the appellant guilty of kidnapping and serious illegal detention

Held: The Supreme Court said that the trial court did not find appellant liable for kidnapping
and serious illegal detention. The Supreme Court, however, finds them guilty the crime slight
illegal detention under Article 268 of the Revised Penal Code. The Supreme Court then modified
the sentence.