G.R. No. 190340 - People vs. Ramos

The case involved the People of the Philippines as Plaintiff-Appellee versus Noel Santos y Crispino (accused-appellant) and Feliciano Funcion, alias Jon-Jon (accused-at-large).
The charge was for violating Republic Act No. 6539, as amended (the Anti-Carnapping Act), which, among other things, penalizes the taking of a motor vehicle by means of violence.
The trial court in Pasay City, Branch 117, convicted Noel Santos y Crispino and sentenced him to reclusion perpetua, along with additional penalties and indemnifications.

On or about June 18, 1995, in Pasay City, the Information alleged that the accused, along with an accomplice, took a Toyota Tamaraw FX owned by Teodulo Natividad y Dela Cruz.
The taking of the vehicle was done with the intent to gain, and by means of violence, whereby the victim, Ruel Valentino Morales, sustained injuries that eventually led to his death.
The vehicle was later found speeding in a provincial area in Magalang, Pampanga, in circumstances that raised suspicion among law enforcement officials.

Galang, a traffic officer stationed in Dolores, Magalang, Pampanga, observed an “overspeeding” Toyota Tamaraw FX at approximately 2:30 a.m. on June 19, 1995.
On directing the vehicle to pull over and upon inspection, Galang discovered that the driver (accused-at-large Jon-Jon Funcion) was in possession of an expired driver’s license issued in the victim’s name.
As Galang attempted to inspect the vehicle further, the driver fled, leaving behind significant evidence.

The rear portion of the vehicle housed the body of Ruel Morales, wrapped in seat covers and curtains.
Recovered articles included a blood-stained kitchen knife, a stone, personal belongings of both the victim and accused-appellant, and other items such as a Certificate of Registration, identification papers, and wallets.

Multiple witnesses, including traffic aides and friends of the victim, testified to the sequence of events leading up to and after the crime.
An autopsy performed by Dr. Ma. Lourdes Natividad revealed that the victim died due to hemorrhage resulting from a fractured skull, with additional injuries including multiple lacerations, incisions, and a ligature mark on the neck.
Evidence from the crime scene and subsequent police interviews tied the presence of accused-appellant in the vehicle with the discovery of the victim’s body.

Noel Santos y Crispino testified that on the night of June 18, 1995, he was involved in a casual gathering at the Malvar Sports Complex in Bangkal, Makati City.
He recounted that he later accompanied accused-at-large Jon-Jon Funcion to a vehicle after a series of events involving an attempted borrowing of money.
According to his version, upon boarding the vehicle, he discovered unusual behavior and later found that he had been forced to obey the instructions of Jon-Jon, including witnessing the concealment of a dead body.
He maintained that he acted under duress and that his actions, including not escaping from the vehicle or resisting arrest, were due to his fear of accused-at-large Jon-Jon.

A unity of purpose and implied conspiracy between Noel Santos and Feliciano Funcion.
That accused-appellant’s presence in the vehicle with the recovered evidences (i.e., the body and personal effects) indicated his participation in the crime.
The application of a presumption that unexplained possession of the victim’s effects rendered Santos the author of the aggression and the murder.

Based on these findings, the trial court convicted Noel Santos y Crispino beyond reasonable doubt.

Whether the prosecution was able to establish, beyond reasonable doubt, that Noel Santos was the perpetrator of carnapping as defined under the Anti-Carnapping Act.
Whether the evidence presented sufficiently proved that Noel Santos participated in the conspiracy and the violent act that led to the death of Ruel Morales.

Whether the presumption that a person found in unexplained possession of stolen effects can be directly equated with being the author of the aggressive act and death.
Whether the trial court erred in inferring a unity of purpose or implied conspiracy between Noel Santos and Feliciano Funcion solely from circumstantial evidence.

Whether Noel Santos’s presence in the vehicle and conduct during arrest, although circumstantially incriminating, are sufficient to overcome his defense of duress.
Whether his explanation regarding his captive status and the events inside the vehicle was properly scrutinized against the circumstantial evidence.