Case Summary (G.R. No. 128056-57)
Criminal Charges and Proceedings
The accused were jointly tried in the Regional Trial Court of Tayug, Pangasinan, Branch 52, where they faced two separate charges: Criminal Case No. T-1698 for murder under Article 248 of the Revised Penal Code and Criminal Case No. T-1699 for carnapping under Republic Act No. 6539 (Anti-Carnapping Law). The trial court found the accused guilty of both crimes, imposing the death penalty on each, along with various damages to be paid to the heirs of the victim in Criminal Case No. T-1698.
Summary of Events
On June 7, 1995, Lito Ignacio, the victim, was hired by the accused to drive a tricycle. The planned vehicle theft escalated into a violent confrontation, where Ignacio was attacked with a stone and shot. His body was later discovered, prompting an investigation that led to the arrest of the accused, who subsequently confessed to the crimes and gave detailed accounts of their actions during a court trial.
Defense Arguments
The accused-appellants primarily contested the nature of the charged crimes. They argued that the killing of Ignacio amounted only to homicide rather than murder and contested the imposition of the death penalty for the carnapping charge, asserting that the correct penalty should be reclusion perpetua instead.
Trial Court's Findings
The trial court identified the presence of an aggravating circumstance—taking advantage of superior strength—during the assault on Ignacio, justifying the classification of the killing as murder. However, the court faced scrutiny for not explicitly charging the aggravating circumstance in the information.
Legal Analysis of the Charges
While the trial court deemed the crime as murder due to the use of superior strength, the Supreme Court highlighted a critical legal error: the aggravating circumstance of superior strength was not alleged in the charging document. According to procedural rules, this omission precluded its use to elevate the charge to murder.
Distinction Between Crimes
The Supreme Court articulated a clear distinction between carnapping and murder, emphasizing that the two charges must be treated distinctly unless the killing is directly tied to the commission of the carnapping. The absence of allegations connecting the victim's killing with the carnapping in the information filed necessitated separate treatments for each charge.
Appropriate Penalties
In view of the findings, the Supreme Court modified the trial court's rulings, determining that the accused could only be convicted of homicide rather than murder in Criminal Case No. T-1698 due to the lack of allegations of the qualifying circumstances. The applicable penalty was adjusted to reflect an indeterminate sentence of ten years and one day of prision mayor to twenty years of reclusion temporal.
For Criminal Case No. T-1699 regarding the carnapping charge, it was concluded that because the killing was not alleged in the information, an appropriate indeterminate sentence of seventeen
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Case Background
- The case involves a review of the decision from the Regional Trial Court of Tayug, Pangasinan, Branch 52, which convicted the accused-appellants for Murder and Carnapping.
- The accused-appellants are Marcos Paramil y Carurucan, Danilo dela Cruz y Vicente, and William Osotio @ "Iyok".
- They were sentenced to death for both crimes committed on June 7, 1995.
Dispositive Portion
- The trial court found all three accused guilty of Murder (Criminal Case No. T-1698) with the aggravating circumstance of superior strength, sentencing each to death and ordering them to pay various damages to the heirs of the victim, Lito Ignacio.
- In Criminal Case No. T-1699, the accused were found guilty of violating the Anti-Carnapping Law, also resulting in a death penalty.
Summary of Charges
- Criminal Case No. T-1698:
- On June 7, 1995, the accused, armed with a firearm and a stone, conspired to kill Lito Ignacio, resulting in his death.
- Criminal Case No. T-1699:
- The accused conspired to take away a Yamaha motorcycle from its driver, Lito Ignacio, without consent.
Arraignment and Pleas
- During arraignment on September 20, 1995, Danilo dela Cruz and William Osotio pleaded not guilty to Murder while Marcos Paramil y Carurucan did not enter a plea, resulting in a not guilty plea being entered for him.
- All accused-appellants pleaded not guilty to the charge of carnapping.
Factual Background
- Lito Ignacio was last seen on June 7, 1995, driving a tricycle owned by Nelson Aquino.
- The victim did not return the tricy