Case Digest (G.R. No. 216015)
Facts:
People of the Philippines v. Jesusano Arcenal y Aguilan, G.R. No. 216015, March 27, 2017, Supreme Court Second Division, Peralta, J., writing for the Court.The People of the Philippines (plaintiff-appellee) prosecuted Jesusano Arcenal y Aguilan (accused-appellant) for violation of R.A. No. 6539 (Anti‑Carnapping Act, as amended by R.A. No. 7659), charging him with carnapping with homicide arising from events on or about April 11–12, 2000. The Information alleged that Arcenal, by force and at night, took a Yamaha tricycle (Plate No. DT‑6680) owned by Renato de Rama, and that the driver, Alvin de Rama, was assaulted with a deadly weapon and killed in the course of the carnapping.
At arraignment on May 17, 2000, Arcenal pleaded not guilty and trial ensued. The prosecution presented eyewitness testimony that Alvin was last seen at about 11:00 p.m. of April 11, 2000, leaving a tricycle terminal with Arcenal as his backrider; approximately 15 minutes later Arcenal was observed driving Alvin’s tricycle alone. Alvin’s body was found at about 6:05 a.m. on April 12 at Forest Park with multiple gaping head wounds and intra‑cranial hemorrhage; bloodstains were found on the recovered tricycle. A dactyloscopy report matched fingerprints lifted from the tricycle to Arcenal. Police could not initially locate Arcenal; he was arrested in 2002 after a tip.
Arcenal’s defense asserted an alibi: he claimed to have been in Barangay Aplaya (Pila) and later in Batangas City on April 11–12, 2000, and only returned shortly before his arrest in 2002. He offered no corroborating witnesses or documentary evidence.
The Regional Trial Court (RTC), Branch 27, Santa Cruz, Laguna, convicted Arcenal of carnapping with homicide and sentenced him to reclusion perpetua and ordered damages (the RTC’s original dispositive awarded reclusion perpetua and specified amounts). The Court of Appeals (CA), in CA‑G.R. CR‑HC No. 05000, affirmed the RTC “in toto,” finding that circumstantial evidence formed an unbroken chain proving Arcenal’s guilt. The CA issued its fallo affirming the conviction.
The case was brought to the Supreme Court for review from the CA decision. The Office of the Solicitor General o...(Pro-only)
Issues:
- Did the prosecution establish beyond reasonable doubt, primarily by circumstantial evidence, that Jesusano Arcenal committed carnapping with homicide?
- Were the penalty and damage awards properly imposed and, if so, i...(Pro-only)
Ruling:
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Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)