Case Digest (G.R. No. 138470)
Facts:
People of the Philippines v. Artemio Garcia y Cruz, Jr. and Regalado Bernabe y Orbe, G.R. No. 138470, April 01, 2003, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court. The accused were tried by the Regional Trial Court (RTC) of Malolos, Bulacan, Branch 21, in Criminal Case No. 830‑M‑98; Judge Cesar M. Solis penned the trial court decision.The basic facts, as found by the trial court and recounted on appeal, are that on 17–18 December 1996 Ar_temio Garcia_ and Regalado Bernabe (the accused) negotiated through Joselito Cortez to use a newly purchased Toyota Tamaraw FX belonging to Ferdinand Ignacio. Cortez had leased the vehicle from Ignacio and in turn rented it to the accused. On 18 December 1996 the vehicle was driven by its driver, Wilfredo Elis, with the accused aboard; the accused left ostensibly for Bicol. When the accused failed to return or communicate for several days, Cortez and Elis’s wife grew concerned.
On 23 December 1996 police in Moncada, Tarlac were alerted that two suspicious persons were trying to sell a vehicle at an unusually low price; the suspects (Garcia and Bernabe) were located in Nampicuan, Nueva Ecija, could not produce ownership papers, and were brought to the Moncada police station. They admitted attempting to sell the Tamaraw FX; Cortez proceeded to Moncada and identified the vehicle. Cortez and Ignacio confronted the detained accused, who — according to Cortez’s testimony — admitted they stabbed and dumped Elis because he refused to join their plan to sell the vehicle. Police later recovered Elis’s body in San Rafael, Bulacan; medico‑legal autopsy revealed multiple stab wounds fatal to the victim.
At trial the prosecution introduced, among others, Cortez’s identification of the vehicle, bloodstains and personal effects of Elis found in the vehicle, the testimony about the search and apprehension, and the autopsy report. The defense claimed the accused rented the van legitimately, that a fight between Garcia and Elis occurred, and that they left Elis along the highway so he could inform Cortez. After trial the RTC found both accused guilty of Carnapping with Homicide under Republic Act No. 6539 and sentenced them to reclusion perpetua, ordering indemnities and damages in favor of the heirs.
Both accused appealed. On March 31, 2000 Garcia filed a motion to withdraw his appeal which the Court granted on September 27, 2000; thus the appeal before the Supreme Court was prosecuted by appellant Bernabe alone. Bernabe raised three assi...(Subscriber-Only)
Issues:
- Was the evidence sufficient to establish beyond reasonable doubt that the accused committed Carnapping with Homicide under R.A. No. 6539, as amended?
- Was conspiracy between Garcia and Bernabe to commit carnapping proven?
- Was appellant Bernabe’s alleged admission to private individuals admissible and properly used against him?
- Were the penalties and civi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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