Facts:

• In the case of People of the Philippines vs. Fabian Urzais y Lanurias (G.R. No. 207662), decided on April 13, 2016, Fabian Urzais y Lanurias and co-accused Alex Bautista and Ricky Bautista were charged with violating Republic Act No. 6539 (Anti-Carnapping Act of 1972), as amended by R.A. No. 7659.
• The charge involved carnapping with homicide using an unlicensed firearm.
• The incident took place on November 13, 2002, in Cabanatuan City.
• The accused allegedly conspired to steal an Isuzu Highlander owned by Mario Magdato.
• During the crime, Magdato was shot and killed with a Norinco cal. 9mm pistol.
• The Regional Trial Court (RTC) of Cabanatuan City, Branch 27, found Urzais guilty beyond reasonable doubt, sentencing him to 40 years of reclusion perpetua.
• The Court of Appeals (CA) affirmed the RTC's decision with some modifications.
• Urzais appealed to the Supreme Court, claiming his conviction was based solely on circumstantial evidence and disputable presumptions, and maintained his innocence.

Issue:

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Ruling:

• The Supreme Court reversed the decision of the Court of Appeals and acquitted Fabian Urzais y Lanurias due to reasonable doubt.
• The Court ordered his imme...(Unlock)

Ratio:

• The Supreme Court stressed that criminal convictions require proof beyond reasonable doubt of both the crime and the identity of the perpetrator.
• The prosecution failed to prove all the elements of carnapping and the accused's role in the crime.
• Evidence mainly included the victim's disappearance, his death, and the accused's possession of the vehicle.
• There was no direct evidence linking Urzais to either the carnapping or the homicide.
• The circumstantial evidence did not form an unbroken chain pointing exclusively to Urzais's guilt.
• The sole evidence of vehicle possession was insufficient for a conviction, especially since Urzais explained his possession by claimin...continue reading