Title
People vs. Ramos
Case Decision Date
G.R. No. 118570 Oct 12, 1998
Benedicto Ramos forcibly abducted Alicia Abanilla, demanded ransom, and
murdered her. The Supreme Court convicted him of kidnapping for ransom
with murder, ruling it a special complex crime under Article 267, imposing
the death penalty.
Jur.ph - Case Digest (G.R. No. 118570)
Direct Answer Model - Expanded
Facts:
In the case of People of the Philippines vs. Benedicto Ramos y Binuya alias "Bennie,"
the accused was found guilty by the Regional Trial Court (RTC), Branch 78 in Quezon
City, of heinous crimes—speci!cally, kidnapping for ransom and murder. The events
unfolded on July 13, 1994, around 6:30 AM, when Malcolm Bradshaw, an American
pastor, observed a woman named Alicia Abanilla struggling and attempting to
escape from a man identi!ed later as Ramos. Despite her desperate attempts to elude
him, including trying to hail a bus and a car, Ramos managed to force his way into
Bradshaw’s vehicle, where they drove together.
During the ride, Abanilla managed to communicate her perilous situation to her
daughter and to Bradshaw, expressing fears for her life. Eventually, they reached a
street in Quezon City where Ramos pulled her out of the car. Alicia Abanilla later
called her boss, Atty. Pastor del Rosario, urgently requesting P200,000.00 for her
immediate release. After relaying her overwhelmingly dire situation, her boss
arranged for the money to be delivered to her.
Subsequently, Ramos and Abanilla took a taxi to a rendezvous point where the
payment was to occur. After the money was delivered, Ramos altered course,
intending to "ee with Abanilla to Bulacan. They arrived in Bocaue, Bulacan, where
Ramos violently restrained Abanilla and shot her in the head when she attempted to
escape. Witnesses, including the taxi driver Antonio Pineda and a tra#c aide, Gil
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Domanais, corroborated the horror of the events. Following the incident, Ramos was
apprehended by the police, where they recovered his !rearm and a signi!cant sum
of money.
In the lower court, Ramos pleaded not guilty but was convicted of two separate
o$enses: kidnapping for ransom and murder, thereby sentencing him to death and
ordering him to pay indemnities for the victim's heirs.
Issue:
1. Was the lower court correct in concluding that Ramos’s guilt for kidnapping for
ransom and murder was proven beyond a reasonable doubt?
2. Did the court err in disregarding certain vital pieces of evidence in favor of
Ramos?
3. Should Ramos have been convicted of a complex crime of kidnapping for
ransom with murder instead of two separate crimes?
Ruling:
The Supreme Court a#rmed the lower court's decision, !nding Ramos guilty of the
special complex crime of kidnapping for ransom with murder. The Court ruled that
the evidence presented was su#cient to establish Ramos's guilt beyond a reasonable
doubt.
Ratio:
The Supreme Court's ruling relied heavily on the testimony of witnesses and the
clear indubitable proof of Ramos's intent to kidnap and murder Abanilla. The Court
stated that the essence of kidnapping involves actual deprivation of liberty, which
was evident in this case as Abanilla was forcibly taken by Ramos and compelled
against her will, armed with a gun. Multiple attempts made by the victim to escape
highlighted the restraint on her freedom.
The argument advanced by Ramos that the victim went with him voluntarily was
dismissed by the Court, emphasizing the profound fear instilled in Abanilla by
Ramos’s threats and actions. The victim's urgent pleas for help to both her daughter
and Atty. del Rosario re"ected her lack of freedom and the imminent danger to her
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life. Furthermore, the demand for ransom by the victim, corroborated by the
surrounding circumstances, was deemed su#cient to substantiate that the
kidnapping was conducted with intent to extort ransom.
On the matter of the murder charge, the Court noted that Ramos's act of shooting
Abanilla was premeditated, qualifying the murder by treachery due to how he !red
at her from behind during her attempt to escape. Thus, the Court concurred with the
lower tribunal that the complexities of these charged o$enses indeed warranted the
imposition of the death penalty.
Doctrine:
The ruling established the principal doctrine that in kidnapping cases, the actual
deprivation of liberty constitutes not just placing a person in a con!ned space but
any actions that signi!cantly restrict a person's freedom. Furthermore, any
subsequent actions resulting in death—whether premeditated or as an afterthought
—would invoke severe charges under the law, as seen in the amendments
introduced to Article 267 of the Revised Penal Code that integrated the concept of
special complex crimes.
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