Title
People vs. Latayada
Case
G.R. No. 146865
Decision Date
Feb 18, 2004
Pedro Payla was stabbed by Elgin Latayada, who fled with Payla's motorcycle. Payla identified Latayada before dying. Latayada escaped trial but was convicted of homicide, not carnapping with homicide, due to insufficient evidence. Treachery was unproven; he was sentenced to 14+ years and ordered to pay damages.

Case Digest (G.R. No. 146865)
Expanded Legal Reasoning Model

Facts:

The Crime and Arrest:
  • On October 29, 1995, Pedro Payla was stabbed by Elgin Latayada while driving his motorcycle in Sitio Hanopolan, Claveria, Misamis Oriental.
  • Payla managed to reach Vicenta Cordino’s house and identified Latayada as his assailant before being taken to the hospital.
  • Payla later died on October 30, 1995.
  • The motorcycle driven by Payla, owned by Rodrigo Estrada, was recovered on November 4, 1995, in a cannibalized state.

Trial Proceedings:

  • Latayada was charged with carnapping with homicide under Republic Act No. 6539 (Anti-Carnapping Act) as amended by RA 7659.
  • During the trial, Latayada escaped detention after the prosecution rested its case and remained at large.
  • The Regional Trial Court (RTC) found Latayada guilty of carnapping with homicide and imposed the death penalty, citing treachery as an aggravating circumstance.

Version of the Prosecution:

  • Payla identified Latayada as his assailant shortly after the stabbing.
  • Witnesses testified that Latayada stabbed Payla and fled with the motorcycle.
  • The motorcycle was later found stripped of its parts.

Version of the Defense:

  • The defense failed to present evidence as Latayada escaped from jail.

Issues:

  • Whether the trial court erred in convicting Latayada of carnapping with homicide despite insufficient evidence.
  • Whether treachery was properly appreciated as an aggravating circumstance.
  • Whether the penalty imposed was appropriate.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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