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PEOPLE v. RENATO LAGAT Y GAWAN

FACTS:

Accused-appellants Renato Lagat y Gawan (Lagat) and James Palalay y Villarosa (Palalay) were charged with the crime of Carnapping and murder. The information alleged that Lagat and Palalay unlawfully took the tricycle owned by Jose Biag, and in the course of the carnapping, they assaulted and killed Biag. Certain facts were admitted during the pre-trial conference, including the recovery of Biag's cadaver, the arrest of Lagat and Palalay in possession of stolen palay, and the cause of Biag's death being multiple stab and hack wounds. The prosecution presented witnesses such as Biag's wife, the Chief Tanod of Barangay Rizal, and a police officer. The witnesses testified on the circumstances leading to Biag's disappearance, the recovery of the tricycle, and the identification of Biag's body. Another police officer presented the accused's confessions stating that they had killed Biag. The prosecution also submitted a post-mortem autopsy report indicating the cause and date of Biag's death. The accused filed a Motion to Dismiss on Demurrer to Evidence, claiming violations of their constitutional rights and insufficiency of circumstantial evidence. The accused waived their right to present evidence. The RTC found the accused guilty of qualified carnapping and ordered them to pay damages to the victim's family. The accused filed a motion for reconsideration, contesting the RTC's reliance on the testimonies of the prosecution's witnesses and circumstantial evidence.

ISSUES:

  1. Whether the confession or admission made by the accused, when they were apprehended by the police without the presence of counsel, is admissible as evidence against them.

  2. Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the accused beyond reasonable doubt.

  3. Whether the elements of carnapping are present in this case.

  4. Whether the guilt of the accused can be proven beyond reasonable doubt based on circumstantial evidence.

  5. Whether or not the crime committed by the accused should be considered as qualified carnapping.

  6. Whether or not the penalty of reclusion perpetua was properly imposed.

RULING:

  1. The confession or admission made by the accused when they were apprehended by the police without the presence of counsel is inadmissible as evidence against them. The absence of counsel to assist them renders their admissions involuntary and inadmissible.

  2. The circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the accused beyond reasonable doubt. The Court of Appeals held that the elements of carnapping were all present in this case and that the circumstantial evidence supported the conviction of the accused.

  3. The elements of carnapping are present in this case. The tricycle, which belongs to the victim, was found in the possession of the accused. The accused fled the scene when approached by the police, and failed to provide any explanation for having the tricycle. These circumstances raise the presumption that they were responsible for the unlawful taking of the tricycle.

  4. The guilt of the accused can be proven beyond reasonable doubt based on circumstantial evidence. The combination of circumstances presented, including the possession of the stolen tricycle, the presence of the accused at a palay buying station with the tricycle filled with stolen cavans of palay, their attempt to flee when approached by the police, their inability to explain their possession of the tricycle, the presence of the victim's wallet and registration papers in the tricycle, and the victim's body bearing hack wounds, leads to the conclusion that the accused conspired to kill the victim in order to steal his tricycle. The pieces of circumstantial evidence presented by the prosecution establish their guilt beyond reasonable doubt.

  5. Yes, the crime committed by the accused should be considered as qualified carnapping. The killing of the victim in the course of the carnapping qualifies the crime and increases the penalty. Pursuant to Section 14 of Republic Act No. 6539, as amended, the penalty for carnapping is reclusion perpetua to death when the owner, driver, or occupant of the carnapped motor vehicle is killed. In this case, the accused killed the victim in order to take his tricycle.

  6. Yes, the penalty of reclusion perpetua was properly imposed. Since no aggravating circumstance was present in the commission of the crime, the Regional Trial Court correctly imposed the penalty of reclusion perpetua.

PRINCIPLES:

  • Admissions made by an accused during custodial investigation without the assistance of counsel are inadmissible as evidence against them.

  • Circumstantial evidence can be sufficient to prove the guilt of an accused beyond reasonable doubt if it excludes every hypothesis consistent with innocence.

  • The elements of carnapping under the Anti-Carnapping Act of 1972 are: (1) actual taking of the vehicle; (2) the vehicle belongs to a person other than the offender; (3) the taking is without the consent of the owner or by means of violence or intimidation; and (4) the offender intends to gain from the taking of the vehicle.

  • Unexplained possession of stolen property raises the presumption that the possessor was responsible for the unlawful taking.

  • Intent to gain in carnapping cases is an internal act, presumed from the unlawful taking of the motor vehicle, and is not limited to pecuniary benefit but also includes any benefit derived from the act.

  • Circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts from which the inferences are derived are proven, and the combination of all the circumstances results in a moral certainty that the accused, to the exclusion of all others, is the one who committed the crime. The combination of circumstances must be interwoven in such a way as to leave no reasonable doubt as to the guilt of the accused.

  • When a person is killed or raped in the course of or on the occasion of carnapping, the crime of carnapping is qualified and the penalty is increased.

  • The penalty for carnapping is reclusion perpetua to death when the owner, driver, or occupant of the carnapped motor vehicle is killed.

  • The accused are jointly and severally liable for the loss of the earning capacity of the victim. Documentary evidence is usually required to substantiate the claim for damages, but exceptions apply for self-employed individuals earning less than the minimum wage or daily wage workers earning less than the minimum wage.