G.R. No. 200512. June 7, 2017 PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELMER AVANCENA y CABANELA, JAIME POPIOCO y CAMBAYA and NOLASCO TAYTAY y CRUZ, accused-appellants. Ponente: J. Leonen; Doctrines: In kidnapping for ransom, the prosecution must be able to establish the following elements: [first,] the accused was a private person; [second,] he [or she] kidnapped or detained or in any manner deprived another of his or her liberty; [third,] the kidnapping or detention was illegal; and [fourth,] the victim was kidnapped or detained for ransom. Accused-appellants claim that they were agents of the Philippine Drug Enforcement Agency’s Task Force Hunter but were unable to present any evidence to substantiate their claim. The prosecution, however, was able to present Police Inspector Nabor of the Human Resource Service of Philippine Drug Enforcement Agency, who testified that accused-appellants “[were] not in any manner connected with [Philippine Drug...
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