Title
People vs. Mallari
Case
G.R. No. 179041
Decision Date
Apr 1, 2013
Reynaldo Mallari is found guilty beyond reasonable doubt of carnapping with homicide after being involved in a conspiracy to steal a vehicle and killing the driver, resulting in a modified penalty of reclusion perpetua.
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Case Digest (G.R. No. 179041)

Facts:

  • Reynaldo Mallari, along with Arnel Nocum, Rey Johnny Ramos, Carlos Jun Posadas, and Pandao Poling Pangandag, was charged with carnapping with homicide, violating Republic Act No. 6539 as amended by RA 7659.
  • The incident occurred on September 12, 1998, in Muntinlupa City, where the accused conspired to steal a Toyota Tamaraw FX vehicle driven by Erico Medel, who was subsequently killed.
  • Mallari was the only one apprehended; his co-accused remained at large.
  • Chris Mahilac, a former member of the "FX gang" and now a state witness, testified against Mallari, detailing the gang's modus operandi and Mallari's involvement.
  • Mahilac's testimony included the planning meeting in Muntinlupa, the actual carnapping, and the subsequent killing of Medel.
  • Mallari denied any involvement, claiming he was at home during the incident.
  • The Regional Trial Court (RTC) found Mallari guilty and sentenced him to death, which was later modified to reclusion perpetua by the Court of Appeals (CA) due to the prohibition of the death penalty under RA 9346.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court affirmed the CA's decision that Mallari was guilty beyond reasonable doubt of carnapping with homicide.
  2. The Supreme Court modified the penalty from death to...(Unlock)

Ratio:

  • The Supreme Court held that the prosecution successfully proved the elements of carnapping with homicide through circumstantial evidence.
  • Mahilac’s testimony, which detailed the planning and execution of the crime, was found credible and sufficient.
  • The court noted that Mahilac had no motive to falsely accuse Mallari, and his testimony was corroborated by the discovery of ...continue reading

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