Facts:

In the case involving Antonio Andres and Rodolfo Duran (Petitioners) and the People of the Philippines (Respondent), the events occurred on September 6, 2002, in Sta. Maria, Bulacan, Philippines. The petitioners were charged before the Regional Trial Court (RTC), Branch 18, Malolos City, with the violation of Republic Act No. 6539, commonly known as the Anti-Carnapping Act of 1992. The information filed against them alleged that they conspired to unlawfully take a Motorized Kawasaki Tricycle, valued at Php 140,000, belonging to Catalino Eugenio without his consent. The petitioners pleaded not guilty at their arraignment, leading to a full trial.

On June 1, 2006, the RTC rendered a decision convicting both petitioners of the charges, sentencing them to serve an indeterminate prison term of seventeen (17) years and four (4) months to thirty (30) years. The petitioners subsequently appealed to the Court of Appeals (CA), which upheld the RTC decision with modification on May 28, 20

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Facts:

Parties and Charges

• Petitioner-defendants: Antonio Andres and Rodolfo Duran.
• Respondent: The People of the Philippines.
• Charged under Republic Act No. 6539 (the Anti-Carnapping Act, as amended).

The Incident

• Date and Location: On or about September 6, 2002, in the Municipality of Sta. Maria, Province of Bulacan.
• Alleged Crime:
• The accused, acting in concert, were alleged to have willfully, unlawfully, and feloniously taken, stolen, and carried away a motorized Kawasaki tricycle valued at P140,000.00.
• The vehicle belonged to Catalino Eugenio, and its unlawful removal resulted in damage and prejudice amounting to P140,000.00.

Proceedings in Lower Courts

• Trial Court (Regional Trial Court, Branch 18, Malolos City, Bulacan):
• Petitioners pleaded not guilty.
• On June 1, 2006, the RTC found petitioners guilty of carnapping as charged.
• The RTC sentenced them to suffer an indeterminate penalty of seventeen (17) years and four (4) months to thirty (30) years imprisonment.
• Court of Appeals Review:
• Petitioners appealed the trial court decision.
• The CA, in its decision (CA-G.R. CR No. 30243), affirmed the conviction with modification of the penalty to seventeen (17) years and four (4) months as the minimum and thirty (30) years as the maximum term.
• Petitioners’ motion for reconsideration before the CA was denied in a resolution dated December 17, 2008.

Issues Raised by the Petitioners

• Identification Concerns:
• Petitioners contended that the eyewitness, Eres Eugenio, could not have positively identified them due to the inadequate lighting conditions (light from a nearby canteen not directed toward their faces).
• It was argued that Eres’ attention was not focused on detailing their identities and that his out-of-court identification was improperly suggestive, thereby failing the "totality of circumstances" test.
• Sufficiency of the Prosecution’s Evidence:
• Petitioners argued that the prosecution failed to prove their guilt beyond a reasonable doubt, particularly given the issues surrounding the eyewitness identification.
• Appropriateness of the Imposed Penalty:
• Even assuming guilt, petitioners claimed that the penalty imposed was erroneous.
• They maintained that the Information did not allege any circumstances (such as violence, intimidation, or use of force) that would justify a penalty higher than that prescribed for simple carnapping under RA No. 6539.

Issue:

Credibility and Reliability of Identification Evidence

• Whether the Court of Appeals erred in giving full credence to the prosecution’s eyewitness identification despite the challenges related to lighting conditions and suggestiveness.
• Whether the defense theory regarding the inadequacy of the witness’s opportunity to see and identify the accused should have been given more weight.

Sufficiency of Evidence to Establish Guilt Beyond Reasonable Doubt

• Whether the prosecution successfully established the accused’s guilt considering the discrepancies and limitations in the identification process.

Appropriateness of the Penalty Imposed

• Whether the imposition of an indeterminate sentence of seventeen (17) years and four (4) months to thirty (30) years was proper when the Information did not allege that the carnapping was committed by means of violence, intimidation, or use of force.
• Whether the proper penalty range should instead align with that for simple carnapping, i.e., imprisonment for not less than fourteen (14) years and eight (8) months to not more than seventeen (17) years and four (4) months.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)