Title
People vs. Arcenal y Aguilan
Case
G.R. No. 216015
Decision Date
Mar 27, 2017
Accused-appellant convicted of carnapping with homicide after stealing a tricycle, killing its driver, and fleeing; evidence included eyewitnesses, fingerprints, and bloodstains. Alibi rejected, reclusion perpetua imposed.

Case Summary (G.R. No. 157838)

Background of the Case

On April 11, 2000, Arcenal allegedly took a Yamaha tricycle belonging to the victim, Alvin de Rama, with intent to steal it. The Information charged him with the unlawful taking of the vehicle by means of violence, leading to the death of Alvin due to injuries inflicted during the incident. The Regional Trial Court (RTC), Branch 27, Santa Cruz, Laguna, found Arcenal guilty of carnapping with homicide and sentenced him to reclusion perpetua.

Proceedings and Findings

During the trial, the prosecution presented eyewitnesses who testified that they saw Alvin and Arcenal together at a tricycle terminal shortly before Alvin was found dead. Evidence included eyewitness accounts, the recovery of the vehicle with bloodstains, and fingerprint analysis matching Arcenal's prints to those found on the tricycle. The prosecution established that after Alvin left the terminal with Arcenal as a passenger, he was later discovered dead in the vicinity where the tricycle was later abandoned.

Defense and Counterarguments

Arcenal denied the accusations, claiming he was elsewhere on the night of the incident and presenting an alibi involving familial obligations. However, the RTC rejected this defense, finding it uncorroborated and riddled with inconsistencies. The court deemed the circumstantial evidence overwhelming, concluding that his alibi lacked credibility.

Elements of the Offense

To convict Arcenal of carnapping with homicide, the prosecution was required to demonstrate: (1) actual taking of the vehicle; (2) ownership of the vehicle belonged to someone other than the offender; (3) taking without consent; (4) use of violence or intimidation; and (5) intent to gain. The court found that the circumstantial evidence and the combination of circumstances presented established Arcenal's presence at the crime scene, his intent to steal the tricycle, and the ensuing homicide of Alvin.

Circumstantial Evidence

Circumstantial evidence presented included Arcenal being the last person seen with the victim, the recovery of the tricycle with blood evidence, and fingerprint matches. The court noted that multiple pieces of circumstantial evidence created a coherent narrative leading to Arcenal's guilt beyond a reasonable doubt. The absence of a

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