Title
People vs. Macaranas y Ferdez
Case
G.R. No. 226846
Decision Date
Jun 21, 2017
Appellant convicted of carnapping with homicide after witness identified him as lookout during fatal motorcycle theft; SC affirmed reclusion perpetua and modified damages.

Case Digest (G.R. No. 226846)
Expanded Legal Reasoning Model

Facts:

  • Incident and Victims
    • On the evening of February 18, 2007, Frank Karim Langaman and his girlfriend, Kathlyn Irish Mae Cervantes, were at Meyland Village, Meycauayan, Bulacan.
    • They were aboard Frank’s motorcycle, a green Honda Wave 125 with Plate No. NQ 8724, registered to Jacqueline Corpuz Langaman.
    • As they prepared to leave, two men wearing jackets and bonnets approached them, followed by a third man (appellant) who was standing near a post.
    • One of the men held Frank by the neck and shot him, causing Frank to fall. The same man pointed the gun at Kathlyn, demanded her cellphone, and hit her on the back when she complied.
    • Kathlyn feigned unconsciousness and observed the men search Frank for valuables.
    • While this occurred, the second man took the motorcycle, and the appellant acted as a look-out.
    • The three men fled on the stolen motorcycle. Kathlyn sought help and Frank was hospitalized.
  • Medical Condition and Death of Victim
    • Dr. Gene Patrick De Leon testified that Frank suffered a gunshot wound traversing the neck requiring surgery.
    • Frank died on March 30, 2007, the 27th postoperative day.
    • The Post-Mortem Certificate cited the cause of death as cardiopulmonary arrest secondary to spinal cord injury with retained metallic foreign body, status post-surgery.
  • Criminal Information and Trial
    • An Information was filed against appellant Jeffrey Macaranas y Fernandez, Richard Lalata, and John Doe charging violation of R.A. No. 6539 (Anti-Carnapping Act) for:
      • The armed, violent, and unlawful taking of the Honda motorcycle without owner’s consent.
      • The killing of Frank Karim Langaman in furtherance of the carnapping.
    • Appellant pleaded not guilty and claimed he was at his father’s house on the day of the incident, asserting an alibi.
    • He also alleged that barangay officials coerced him into confessing and implicating his cousin Richard Lalata.
  • Trial Court Decision
    • The RTC found appellant guilty beyond reasonable doubt of carnapping and imposed:
      • Reclusion perpetua sentence.
      • Civil indemnity of Php 50,000.00.
      • Temperate damages of Php 50,000.00.
      • Actual damages or indemnity of Php 25,000.00 for the motorcycle.
      • Payment of costs.
    • The case against Richard Lalata was archived pending his apprehension.
  • Court of Appeals Decision
    • The CA affirmed the RTC judgment with modifications on damages:
      • Civil indemnity increased to Php 75,000.00.
      • Moral damages fixed at Php 50,000.00.
      • Exemplary damages at Php 30,000.00.
      • Temperate damages at Php 25,000.00 in lieu of actual damages.
    • Interest at six percent per annum was imposed on the damages.
    • The case against Richard Lalata remained archived, with an alias warrant of arrest ordered.
  • Appellant’s Arguments on Appeal to the Supreme Court
    • Contended that the trial court and CA erred in relying on the lone prosecution witness whose testimony he claims was inconsistent and improbable.
    • Maintained his alibi and denied the charges.

Issues:

  • Whether or not appellant Jeffrey Macaranas y Fernandez is guilty beyond reasonable doubt of violation of Republic Act No. 6539 (Anti-Carnapping Act) with the killing of the victim.
  • Whether the defense of denial and alibi was sufficient to exculpate appellant.
  • Proper penalty and damages to be imposed under the amended law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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