Case Summary (G.R. No. 223833)
Factual Background
On August 14, 2012 at about 9:00 p.m., Calderon parked his Racal motorcycle with sidecar outside the Marilao public market in Bulacan. He lent the tricycle’s key to petitioner Joshua Casanas to convey a passenger. Casanas never returned the vehicle. The next afternoon, Calderon reported the disappearance to the Marilao police. On August 19, 2012, Valenzuela City officers found Casanas beside the motorcycle (now sold without its sidecar), arrested him, and brought him to the police station. Casanas admitted borrowing the motorcycle on August 18 but claimed inability to return it due to social drinking; he denied felonious intent.
Trial Court Findings
By Decision dated May 15, 2013, the RTC-Valenzuela convicted Casanas of Carnapping under Section 2 of RA 6539. It held that:
- Initial possession was lawful as a borrowing arrangement.
- Failure to return the vehicle within the agreed period transformed possession into an unlawful taking.
- Continued personal use established intent to gain.
Casanas was sentenced to an indeterminate term of 14 years and 8 months to 15 years.
Court of Appeals Ruling
In its July 28, 2015 Decision, the CA affirmed in toto. It emphasized that:
- Only the motorcycle (without the sidecar) was recovered, underscoring intent to appropriate.
- Casanas never sought Calderon’s permission for extended use nor produced registration papers when confronted by police.
A subsequent motion for reconsideration was denied on January 11, 2016.
Issues Before the Supreme Court
- Whether the RTC-Valenzuela had territorial jurisdiction over the alleged carnapping.
- Whether Casanas’s conviction for Carnapping was correctly upheld.
Supreme Court’s Analysis on Jurisdiction
The Court held that a criminal court’s venue is jurisdictional and may be questioned at any stage. Under Rule 110, Sections 10 and 15(a), an information must allege that the offense or one of its essential ingredients occurred within the court’s territory. Although the information alleged commission in Valenzuela City, both Calderon’s sworn statement and trial testimony placed the taking at the public market in Marilao, Bulacan.
...continue readingCase Syllabus (G.R. No. 223833)
Facts
- On August 12, 2012, petitioner Joshua Casanas y Cabantac, alias Joshua Geronimo y Lopez, allegedly took and carried away a Racal motorcycle (plate no. 7539IJ), attached to a sidecar, without the consent of its owner, Christopher Calderon y Dorigon, in Valenzuela City, as charged in the Information filed August 22, 2012 before RTC-Valenzuela (Criminal Case No. 874-V-12) under RA 6539 (Anti-Carnapping Act), as amended.
- On the evening of August 14, 2012 at around 9:00 PM, Calderon waited at Marilao Public Market, Bulacan, when a passenger arrived and hired his tricycle (motorcycle plus sidecar); Casanas volunteered to drive and took both vehicle components.
- Casanas did not return the tricycle that night, prompting Calderon to report the incident the following afternoon to Marilao police, resulting in a blotter entry.
- On August 19, 2012, Valenzuela City police received a tip that a stolen motorcycle was being sold in Karuhatan, Valenzuela City; PO2 Harvy Arañas and PO1 Elbern Chad De Leon responded.
- The officers found Casanas beside the subject motorcycle; he lacked proof of ownership and was frisked, revealing a knife; Casanas, the motorcycle, and the knife were brought to the station.
- Investigation confirmed the motorcycle’s registration in Calderon’s name; the next day, Calderon recovered his motorcycle.
- Casanas admitted Calderon’s ownership but denied theft, claiming he borrowed the vehicle on August 18, 2012 and failed to return it due to social drinking; he alleged police thereafter apprehended him and framed him over a knife.
Procedural History
- RTC-Valenzuela, Branch 269, rendered a Decision on May 15, 2013, finding Casanas guilty beyond reasonable doubt of carnapping and sentencing him to an indeterminate prison term of 1