Case Digest (G.R. No. 223833)
Facts:
In Joshua Casanas y Cabantac a.k.a. Joshua Geronimo y Lopez v. People of the Philippines (G.R. No. 223833), petitioner Joshua Casanas was charged with carnapping under Section 2 of the Anti-Carnapping Act of 1972 (RA 6539), as amended. The Information, filed on August 22, 2012 before the RTC of Valenzuela City, Branch 269, alleged that on August 14, 2012 at around 9:00 PM in the public market of Marilao, Bulacan, Casanas, with intent to gain, took and carried away a Racal motorcycle with plate number 7539IJ attached to a sidecar without the consent of its owner, Christopher Calderon y Dorigon, to Calderon’s damage and prejudice. Calderon testified and executed a sworn statement confirming that he lent his tricycle keys to Casanas, who never returned the vehicle. On August 19, 2012, police officers in Karuhatan, Valenzuela City, found Casanas beside the motorcycle (the sidecar having been removed), could not produce proof of ownership, and arrested him. Casanas admitted borrowingCase Digest (G.R. No. 223833)
Facts:
- Charging and Accusatory Allegations
- On August 22, 2012, an Information was filed in RTC-Valenzuela, Branch 269, charging petitioner Joshua Casanas y Cabantac, alias Joshua Geronimo y Lopez, with carnapping under Section 2 of RA 6539.
- The Information alleged that on or about August 12, 2012 in Valenzuela City, Casanas willfully and unlawfully took a Racal motorcycle (plate no. 7539IJ) without the consent of its owner, Christopher Calderon y Dorigon.
- Prosecution Evidence
- Christopher Calderon’s Sinumpaang Salaysay (Aug. 21, 2012) and trial testimony established that on August 14, 2012, at around 9:00 p.m., in Marilao Public Market, Bulacan, Calderon lent the tricycle (motorcycle + sidecar) to Casanas for a passenger, but Casanas never returned it.
- On August 19, 2012, police in Karuhatan, Valenzuela City recovered the subject motorcycle (without sidecar) in Casanas’s possession; Casanas lacked proof of ownership and was apprehended with a knife. Calderon later identified and recovered his motorcycle.
- Defense Claim and Lower Court Proceedings
- Casanas admitted possession but claimed he merely “borrowed” the motorcycle on August 18, 2012 and failed to return it due to a drinking session; he denied intent to permanently appropriate.
- RTC-Valenzuela (May 15, 2013) found him guilty beyond reasonable doubt and sentenced him to 14 years and 8 months to 15 years. The CA (July 28, 2015) affirmed; its January 11, 2016 resolution denied Casanas’s motion for reconsideration.
Issues:
- Jurisdiction
- Whether the RTC of Valenzuela City had territorial jurisdiction over the carnapping offense.
- Whether petitioner may question such jurisdiction despite not moving to quash the Information.
- Merits of Conviction
- Whether the CA correctly upheld the finding that Casanas unlawfully appropriated the motorcycle with intent to gain.
- Whether removal of the sidecar and failure to contact the owner support the inference of intent to steal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)