Criminal Law

Annaliza Marzan and Reynold Marzan vs People of the Philippines

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G.R. No. 248905 – Criminal Law – Book I – Criminal Liability; Degree of Participation – Principal vs Accomplice; Conspiracy

Remedial Law – Evidence – Testimonial Evidence – Inconsistencies in the testimony of a witness; when not fatal to the case

Criminal Law – Book II – Crimes Against Liberty – Serious Illegal Detention – Freedom of Locomotion vs Freedom of Movement

In 2007, Bonita Baran was employed by spouses Anna Liza Marzan and Reynold Marzan as their household help in their Quezon City home. In 2008, Anna Liza began maltreating Baran. Anna Liza would physically abuse Baran every time she is not satisfied with Baran’s performance of her chores. Anna Liza would lock her up in certain rooms inside their house. Reynold on the other hand, though he did not physically abused Baran, would lock the main door of the house to ensure that Baran will not escape. As a result of the maltreatment, by 2012 Baran severely lost weight, she incurred multiple injuries, and she even lost her eyesight.

The trial court convicted Anna Liza of Serious Illegal Detention and was sentenced to reclusion perpetua. Reynold on the other hand was convicted as an accomplice and was meted the lesser penalty of prision mayor medium to reclusion temporal medium.

On appeal, the Marzans argued that Baran’s testimony is not credible because of several consistencies, i.e., how could she claim that her freedom was restricted when she could perform household chores and that it was proved that since 2011, there were no doors in the rooms where she was allegedly detained; and how could Anna Liza bang Baran’s head against the overhead kitchen cabinet when the kitchen cabinet was six feet above the ground.

ISSUE: Whether or not the convictions must be affirmed.

HELD: YES but with modifications. The conviction as against Anna Liza cannot be carried out because she died pending appeal. Hence, the case against her is dismissed. As against Reynold, he is not simply an accomplice. He is a co-conspirator. Reynold’s act of locking the main door of the house was in furtherance of the crime perpetrated by Anna Liza. Their synchronized actions before, during, and after the detention showed they acted in conspiracy with each other to attain a common objective: to detain Baran against her will. In conspiracy, the act of one is the act of all.

The inconsistencies in Baran’s testimony are minor. In fact, minor inconsistencies tend to strengthen the credibility of the witness because it shows that the testimony was not rehearsed. Surely, as between Baran’s categorical testimony, on one hand, and the Marzan’s mere denial and alibi, on the other, the former prevails. More so because Baran was not shown to have been moved by any ill-will to falsely testify against her former employees.

Anent her freedom inside the house, even assuming that Baran can move around the house to do her assigned chores, her movements were, nonetheless, restricted. Baran may have “freedom of locomotion, but not freedom to leave at will.” The multiple injuries inflicted and suffered by Baran lend credence to her testimony that she got so scared of Anna Liza and had no choice but to just remain still and suffer her detention in silence.

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