Title
People vs. Lobitania
Case
G.R. No. 142380
Decision Date
Sep 5, 2002
SPO1 Lobitania convicted of aggravated carnapping with murder after forcibly taking a tricycle, killing its driver; death penalty upheld due to abuse of superior strength.

Case Digest (G.R. No. 142380)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Accused-Appellant: SPO1 Danilo Lobitania, member of Navotas PNP-NPD Command, charged with aggravated carnapping with murder.
    • Victim/Owner: Alexander de Guzman, driver of a Yamaha tricycle (Plate No. 2N-7910) owned by David Sarto.
  • Commission of the Crime
    • December 5–6, 1998: Lobitania recruited Jolito Sanchez and four companions for a job in Pangasinan; they boarded a bus to Urdaneta City.
    • Upon arrival, they flagged down de Guzman’s tricycle in Barangay Nancayasen. Montolo shot the driver in the chest; Sidro bound de Guzman’s hands and shoved him out, causing instantaneous death; the group then took the tricycle.
  • Post-Crime Developments
    • Sanchez and Jr. Saburin were threatened at gunpoint to accompany the group, then abandoned in a sugarcane plantation; they escaped around 3 a.m., returned to Manila, and reported to PAOCTF.
    • Barangay authorities in San Manuel, Tarlac, recovered the sidecar and motorcycle; owner David Sarto identified them; autopsy confirmed death by hypovolemic shock due to gunshot.
  • Trial and Defense
    • Prosecution Witness: Jolito Sanchez testified as an eyewitness; his credibility was challenged by Lobitania as biased (alleged Tirtir Gang affiliation).
    • Defense of Denial and Alibi: SPO1 Michael Legaspi testified Lobitania was on duty in Manila; wife Valeriana Lobitania corroborated his presence at home from 10 p.m. onward on December 5.

Issues:

  • Whether the prosecution proved beyond reasonable doubt that SPO1 Lobitania is guilty of aggravated carnapping with murder.
  • Whether the award of civil indemnity, moral and exemplary damages was proper.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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