Case Summary (G.R. No. 226846)
Facts Surrounding the Incident
Frank Karim Langaman suffered a gunshot wound to the neck inflicted by one of the three assailants. After subduing Frank and intimidating Kathlyn, one man took Frank’s motorcycle while the appellant acted as look-out. Frank died due to complications from the gunshot injury. Kathlyn was able to identify the appellant as one of the perpetrators during the incident.
Charges and Trial Court Proceedings
The Information charged Jeffrey Macaranas together with Richard Lalata and John Doe for violation of R.A. No. 6539. The appellant pleaded not guilty and testified in his own defense, presenting an alibi that he was with family on the date of the incident. The trial court found the appellant guilty beyond reasonable doubt, sentenced him to reclusion perpetua, and awarded damages to the private complainants, specifically Jacqueline Langaman, owner of the carnapped motorcycle.
Court of Appeals Decision
The Court of Appeals (CA) affirmed the trial court’s judgment with modifications to the damages awarded, increasing civil indemnity, moral damages, exemplary damages, and temperate damages. The CA also affirmed the penalty of reclusion perpetua. The case against co-accused Lalata remains archived pending his apprehension.
Applicable Law: Anti-Carnapping Act and Amendments
Under Section 14 of R.A. No. 6539, as amended by R.A. No. 7659, carnapping is penalized with imprisonment ranging from 14 years and 8 months to 30 years, depending on the presence of violence or intimidation. When the victim is killed or raped in the course or occasion of carnapping, the penalty is reclusion perpetua to death. The amendment clarifies that the killing must occur “in the course of the commission of the carnapping or on the occasion thereof,” establishing carnapping with homicide as a special complex crime.
Elements of Carnapping with Homicide
To convict for carnapping with homicide, the prosecution must establish:
- Actual taking of a motor vehicle;
- Vehicle belonging to another person;
- Taking done without the consent of the owner or by means of violence or intimidation;
- Intent to gain from the taking;
- The original criminal design was carnapping;
- Killing of the victim occurred during or on the occasion of the carnapping.
Nature of Carnapping as a Special Crime
Carnapping is distinguished from robbery and theft under the Revised Penal Code in that it specifically relates to motor vehicles. It involves unlawful taking with intent to gain either with or without the use of force. The killing or rape during carnapping qualifies but does not change the fundamental classification of the crime, analogous to the jurisprudence on robbery with homicide.
Credibility of the Witness and Appellant’s Defense
The Court gave significant weight to the victim’s girlfriend’s testimony identifying the appellant. The trial court’s and appellate court’s evaluation of witness credibility were accorded respect, given their direct observation of the witness’ demeanor. The appellant’s defense of denial and alibi was found lacking, as it was uncorroborated by disinterested witnesses and contradicted by the positive identification made during trial.
Conspiracy Among the Accused
The coordinated conduct of the appellant and co-accused indicated conspiracy. The Court recognized the joint collaboration, concerted action, and shared intention to commit carnapping as substantially proven by the concurrent and coordinated acts before, during, and after the crime.
Penalty and Award of Damage
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Case Syllabus (G.R. No. 226846)
Background and Procedural History
- The case involves an appeal of the October 29, 2015 Decision of the Court of Appeals (CA) which dismissed Jeffrey Macaranas y Fernandez’s appeal and affirmed with modification the Judgment dated August 22, 2012 of the Regional Trial Court (RTC), Branch 79, Malolos, Bulacan.
- Jeffrey Macaranas was found guilty beyond reasonable doubt of violating Republic Act (R.A.) No. 6539, known as the Anti-Carnapping Act of 1972, in Criminal Case No. 38-M-2008.
- The Information charged appellant and two others (Richard Lalata and John Doe) with carnaping and the accompanying homicide of Frank Karim Langaman caused during the commission of the crime.
- The case stemmed from events on February 18, 2007, when Frank Langaman was shot and his motorcycle was forcibly taken.
- After affirmation and modification by the CA, Jeffrey Macaranas filed an appeal to the Supreme Court contesting the ruling.
Facts of the Case
- On February 18, 2007, Frank Karim Langaman and his girlfriend Kathlyn Irish Mae Cervantes were in Meyland Village, Meycauayan, Bulacan, on Frank’s green Honda Wave 125 motorcycle.
- Three men approached them: two were wearing jackets and bonnets, and the appellant was standing by a post.
- One of the men held Frank by the neck and shot him; the same person robbed Kathlyn of her cellphone and hit her.
- The second man took the motorcycle; the appellant acted as the look-out and guard.
- The three men fled together on the motorcycle.
- Frank sustained a gunshot wound to the neck requiring surgery but died on the 27th post-operative day from cardio-pulmonary arrest secondary to spinal injury.
- An Information was filed charging the accused of carnapping with homicide.
Charges and Trial Proceedings
- The charge was violation of R.A. No. 6539 (Anti-Carnapping Act) with attendant homicide due to the fatal shooting of Frank during the commission of the carnapping.
- The appellant pleaded not guilty and claimed an alibi that he was elsewhere at the time.
- Prosecution witnesses included Jacqueline Langaman (owner of the motorcycle's registered name), Kathlyn Cervantes (eyewitness), Dr. Gene Patrick De Leon (medical examiner), and SPO1 Hernan Roble Berciles, Jr. (investigating officer).
- The appellant testified, denying involvement and alleging mistreatment by barangay officials.
- The RTC convicted appellant, sentencing him to reclusion perpetua and ordering indemnities and damages. The case against co-accused Lalata was archived pending apprehension.
Appeal and Affirmation by the Court of Appeals
- The CA denied the appeal but modified damages awarded to the private complainant:
- Increased civil indemnity to Php 75,000.00
- Moral damages set at Php 50,000.00
- Exemplary damages set at Php 75,000.00
- Temperate damages increased to Php 25,000.00 in lieu of actual damages.
- The CA reiterated the conviction under reclusion perpetua and ordered the continuation of the warrant against Lalata.
- The CA gave weight to the testimony of Kathlyn Cervantes identifying appellant as a perpetrator.
Legal Framework: Anti-Carnapping Act, R.A. No. 6539, as Amended
- Carnapping defined as the taking, with intent to gain, of