PEOPLE OF THE PHILIPPINES v.
ABLAZA • Ablaza people was charged with the crime of kidnapping with serious
October 31, 1969 | Per Curiam | Rape
PETITIONER: People of the Philippines
RESPONDENTS: Ruben Ablaza
SUMMARY: Ruben Ablaza forcibly took Annabelle Huggins and
brought her to Bulacan. He allegedly raped Huggins during this
particular abduction. The Constabulary rescued Huggins, which led to
her charging Ablaza with the crime of forcible abduction with rape.
Ablaza forcibly took her again, this time to coerce her to drop the charge
against him. He was eventually apprehended and another crime was
charged against him. The trial court found him guilty of the crime of
kidnapping with serious illegal detention. Ablaza argued that he must be
convicted with rape instead since the testimony contained an allegation
of a rape incident. The Court, however, disregarded his argument and
stated that ther crimes committed in the course of the victim’s
confinement is immaterial.
DOCTRINE: The fact that there may have been other crimes committed
in the course of the victim’s confinement is immaterial to this case. No
doctrine related to rape
RANDOM FACT: The victim in this case, Annabelle Higgins, worked
with Jack Nicholson in Back Door to Hell. This case is also highly
publicized.
FACTS:
• Ruben Ablaza forcibly took Annabelle Huggins from her aunt’s place
and brought her to a house in Bulacan. She was criminally and sexually
abused by Ablaza
• Huggins was eventually rescued by the Philippine Constabulary. After
that, a criminal action for forcible abduction with rape was filed.
• Months later, Huggins was again forcibly taken, this time by two people.
She was dragged inside a taxicab where Ablaza is waiting.
• Huggins was taken to Malolos, Bulacan and was asked to drop the
complaint against Ablaza.
• Huggins was again rescued by the Constabulary.
illegal detention.
• Ablaza offered a different story. He testified that he is in a relationship
with Huggins. They decided to elope due to Huggins’ aunt. They were
discovered, however, which led to the charge of abduction with rape
against him.
• Months after, he received a letter from Huggins asking him to fetch her.
Huggins went inside the cab. They even agreed to get married while
inside the cab. Ablaza suggested that they first go to Malolos so the
charge against him be dropped. This led to his arrest in the hands of the
Philippine Constabulary.
• The trial court found Ablaza guilty of the crime of kidnapping with
serious illegal detention. The trial court appreciated the testimony of
Huggins instead of the defense of Ablaza.
ISSUE/s:
WoN the criminal charge against him was proper - YES
RULING: SC upheld the trial court’s decision.
RATIO:
• Ablaza argued that he should be convicted with the crime of rape rather
than the crime of kidnapping with serious illegal detention.
• There is no merit in the allegation.
• The essential element of the crime of kidnapping with serious illegal
detention is the deprivation of the liberty of the victim. This has been
duly proven.
• The fact that there may have been other crimes committed in the course
of the victim’s confinement is immaterial to this case. Therefore, the
argument of Ablaza has no merit.
• Kidnapping becomes consummated when the victim has been restrained
or deprived of her freedom.
• The surrounding circumstances make it clear that the main purpose of
Annabelle’s detention was to coerce her into withdrawing her previous
charge against appellant Ablaza, thus obstructing the administration of
justice.
• The acts of rape were incidental and used as a means to break the girl’s
spirit and induce her to dismiss the charge.
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