People v Flores

G.R. No. 116488. May 31, 2001

Art. 124 - Arbitrary Detention

Facts:

·                The victim, Samson Sayam, was drinking beer at the store when the defendants were at the same store drinking beer.

·                Sayam joined the four accused at their table. Then, all the accused and the victim left the store and walked towards the direction of the military detachment headquarters. After the accused left the store with Samson Sayam, witnesses heard a single gunshot followed by rapid firing coming from the direction of the detachment headquarters. That was the last time Samson Sayam was seen, and despite diligent efforts of Sayam's mother and relatives, he has not been found.

·                The trial court gave credence to the prosecution's evidence that Samson Sayam was seen being forcibly dragged out of the store and pulled towards the direction of the detachment headquarters by the accused.

·                Since Samson Sayam had not been seen nor heard from since then, the trial court held that the three accused were responsible for the former's disappearance.

·                They should be acquitted of the offense charged against them because they were not private individuals at the time of the commission of the alleged crime.

·                The Solicitor General recognizes the error and submits that, under the facts alleged, accused-appellants can only be liable for the crime of Arbitrary Detention.

Issue:

            WoN the accused-appellants are guilty of Arbitrary Detention.

  

Held:

           No, a careful review of the records of the instant case shows no evidence sufficient to prove that Samson Sayam was detained arbitrarily by accused-appellants.

Based on the testimony of the prosecution witnesses, there is no shred of evidence that he was actually confined there or anywhere else. The fact that Samson Sayam has not been seen or heard from since he was last seen with accused-appellants does not prove that he was detained and deprived of his liberty.

Even the circumstantial evidences when presented were not sufficiently proven by material or relevant testimony, and do not support a judgment or conviction.

In fact, the disappearance of the victim has no bearing in this case because it is not one of the elements of the crime of arbitrary detention.

           Thus, the Court reverses the decision of the trial court and acquits the accused.