Valenton, Francis Angelo T.

Criminal Law 2

1S

People vs. Rodrigo (G.R. No. 173022)

Facts: The appellee is the People of the Philippines. The appellants are Darius Rodrigo,
Feliciano Fajardo, Tinga, Jr., and Rey Plata, Chico-Nazario. In the case at bar, on September 10,
1996, Oliver Caparas, then 13 years of age, was waiting for a ride to school in a corner near his
house in Malolos, Bulacan. Suddenly four men seized and boarded him into a car. He was then
blindfolded. He was later transferred to a van, which was tailed by a car, then traveled to Baguio.
While there, they slept overnight inside the van in a parking lot. The next day, Eleazar Caparas
the father of Oliver, received a call from the alleged kidnappers initially asking for P10 million
ransom in exchange for the release. Meanwhile the kidnappers proceeded to Bonitas Resort in
Pangasinan. The victim was then brought to a room and his blindfold removed. He stayed inside
the room for one week. On September 17, 1996, an uncle of Oliver, was instructed by the father
to deliver the ransom money. He then proceeded to follow the instructions on the drop-off of the
money. He eventually gave the money to a man whom he would later describe as mestizo. Later
that night, the victim and the father were able to reunite. Later on the herein appellants were
arrested and charged with Kidnapping for Ranson. They were found guilty of the same

Issue: Are the appellants guilty of Kidnapping for Ransom.

Held: The Supreme Court said that the appellants are guilty of Kidnapping for Ransom. With
the exception for the two appellants. These are Rey Plata and Feliciano Fajardo, Jr. It is for the
reason that they were not proved to be conspirators with the other appellants. With respect to the
rest of the appellants, all the elements under Article 267 of the RPC were present. These are: “(1)
the offender is a private individual; (2) he kidnaps or detains another, or in any manner deprives
the latter of his liberty; (3) the act of detention or kidnapping must be illegal; and (4) in the
commission of the offense any of the following circumstances is present: (a) the kidnapping or
detention lasts for more than three days; (b) it is committed by simulating public authority; (c)
serious physical injuries are inflicted upon the person kidnapped or detained or threats to kill him
are made; or (d) the person kidnapped and kept in detained is a minor, the duration of his
detention is immaterial”