G.R. No. 196110 - PNCC Skyway Corp. vs. Secretary of Labor and Employment

The case involves the accused-appellant Enrile Donio y Untalan, charged with violation of Republic Act No. 6539 (the Anti-Carnapping Act of 1972, as amended by R.A. No. 7659).
Co-accused, namely Val Paulino and “one @Ryan,” were similarly charged; however, the latter two remain at-large.

On or about November 26, 2003 in the Municipality of Mabalacat, Pampanga, the accused, by means of conspiracy, confederation, and mutual assistance, allegedly took, stole, and carried away one (1) Honda TMX 155 tricycle (Body No. 817) valued at ₱96,000.00.
During the commission of the offense, Raul L. Layug—being both the driver and the owner of the said tricycle—was fatally injured by a mini jungle bolo, which had bloodstains on it.

On November 26, 2003, six police officers from the Concepcion Police Station in Tarlac City, headed by SPO4 Leodegario Taberdo, conducted a checkpoint along MacArthur Highway as part of the police campaign against hijacking, carnapping, and kidnapping.
At approximately 2:30 in the morning, a speeding tricycle abruptly stopped near the checkpoint, attracting police attention.
SPO4 Taberdo, together with his colleagues, approached the vehicle and observed that the driver, later identified as Donio, displayed agitated behavior including kicking the tricycle’s starter.
When questioned about his identity, the driver introduced himself as “Raul Layug” and produced a temporary license bearing the same name.
The vehicle’s failure to produce its official documents raised suspicion, and upon conducting a visual search, the police discovered a bloodstained mini jungle bolo inside the tricycle.
The tricycle, along with the bolo, was seized; Donio, along with his companions Paulino and Ryan, was brought to the police station.

At 9 o’clock in the morning, Donio requested permission to leave the station to fetch the tricycle’s registration papers but failed to return.
Concurrently, Rodrigo Layug, the brother of the victim Raul, initiated a search for Raul, prompted by his prolonged absence.
Through inquiries with local tricycle drivers and relatives, it was confirmed that Raul was last seen driving his own tricycle and that his body—with multiple stab wounds—was later found in a vacant lot.
The identification of Donio was later corroborated when SPO4 Taberdo, upon being queried about the missing driver incident, recognized him and confirmed his real identity.

During trial at the Regional Trial Court (RTC), Branch 59 in Angeles City, Donio, assisted by his counsel de oficio, pleaded not guilty to the charges.
The trial court evaluated the circumstantial evidence which included the police checkpoint apprehension, the discovery of incriminating physical evidence (such as the bolo), and Donio’s inconsistent statements regarding his identity and actions.
The RTC convicted Donio of the crime of carnapping with homicide, holding that the prosecution successfully established the necessary elements—unlawful taking, intent to gain, and the qualification that the killing occurred during the commission of carnapping.
Donio’s unsubstantiated alibi and inconsistent claims of torture and mistreatment during arrest failed to rebut the weight of the circumstantial evidence.

On November 4, 2013, the Court of Appeals (CA) affirmed the RTC’s decision, rejecting the accused’s arguments, including the claim of error in the indictment’s caption and his allegations of torture.
The CA found that the circumstantial evidence—inclusive of positive police identification, failure to produce proper documentation by the accused, and corroborative forensics—established Donio’s guilt beyond reasonable doubt.
The appellate court also noted that any error in the labeling of the crime does not vitiate the substance of the charge so long as the facts clearly support the commission of the offense.
The case was then elevated to the Supreme Court on appeal, which, after a detailed review of the records and submissions, found no compelling reason to reverse the conviction.

Whether the prosecution has proved beyond reasonable doubt that Donio is guilty of the crime of carnapping with homicide.
Whether the circumstantial evidence provided—such as the police identification, possession of the stolen tricycle without proper documents, and forensic evidence regarding the victim’s fatal injuries—is sufficient to sustain the conviction.
Whether Donio’s defense of an uncorroborated alibi and his claims of being tortured during arrest can negate the prosecution’s evidence.
Whether an error in the designation of the offense in the Information (i.e., misnaming the crime) constitutes a fatal defect affecting the validity of the indictment.