Facts:
People of the Philippines charged
Enrile Donio y Untalan with violation of
Republic Act No. 6539 (Anti‑Carnapping Act of 1972), as amended by R.A. No. 7659, alleging that on November 26, 2003 in the Municipality of Mabalacat, Province of Pampanga, he and two at‑large co‑accused, Val Paulino and one Ryan, conspired to take a Honda TMX 155 tricycle (Body No. 817) belonging to Raul L. Layug and that Layug was killed with a mini jungle bolo on the occasion of the carnapping. At a checkpoint along the junction of MacArthur Highway in Concepcion, Tarlac City at about 2:30 a.m. on November 26, 2003, police officers hailed a speeding tricycle driven by the person who identified himself as Raul Layug and who presented a temporary license in that name; the driver failed to produce the vehicle papers, handed a bloodstained mini jungle bolo found inside the tricycle, left the station after being allowed to fetch registration papers but did not return, and was later apprehended and positively identified by SPO4 Leodegario Taberdo as the driver stopped at the checkpoint. The victim’s body was discovered in Barangay Madapdap the next morning with multiple penetrating stab wounds, and Dr. Reynaldo C. Dizon performed the post‑mortem. At trial Donio denied participation, claimed alibi as a stay‑in plantation worker and alleged torture to force a confession; the Regional Trial Court, Branch 59, Angeles City convicted him on January 24, 2012 of carnapping with homicide and sentenced him to
reclusion perpetua with awards of civil indemnity and actual damages, the Court of Appeals affirmed on November 4, 2013, and the present appeal to the Supreme Court ensued, resulting in a decision dated March 1, 2017.
Issues:
Was the prosecution’s evidence sufficient to prove beyond reasonable doubt that
Enrile Donio y Untalan was guilty of carnapping with homicide? Was the misdesignation of the offense in the Information fatal to the prosecution? Were the circumstantial evidence, the presumption from recent possession, and the testimony of SPO4 Taberdo sufficient to overcome Donio’s alibi and torture claims?
Ruling:
Ratio:
Doctrine: