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PEOPLE v. MARLON DELA CRUZ

FACTS:

Two Informations were filed against appellant Marlon dela Cruz, together with Adriano Melecio, Jessie Reyes, and Jepoy Obello before the Regional Trial Court (RTC) of Dagupan City. The first information accused them of violating the Anti-Carnapping Law by stealing a Yamaha motorized tricycle belonging to Juliana Tamin without her knowledge and consent. The second information accused them of robbery with homicide for stealing the earnings and cash money of Teofilo Tamin Sr. amounting to P6,000.00 and driving away his motorized vehicle, and causing his death by attacking and assaulting him. Melecio and Obello remain at large, while dela Cruz and Reyes pleaded not guilty. The evidence presented by the prosecution revealed that the victim was found dead beside his stall, and his motorized tricycle and cash were missing. The autopsy showed that the victim died from intracranial injury and brain hemorrhage caused by mauling. The police recovered the sidecar attached to the motorcycle near the crime scene and received information that dela Cruz and an unidentified man were seen riding a red Yamaha motorcycle. De la Cruz’s friends later revealed that he arrived on a red motorcycle with Melecio, and he admitted to taking the motorcycle from an old man after hitting him with a stone. After trial, the RTC convicted dela Cruz of both charges and acquitted Reyes. The court also ordered dela Cruz to pay indemnity, moral damages, and exemplar to the victim’s wife.

ISSUES:

  1. Whether there was sufficient evidence to support the conviction of appellant for robbery with homicide and violation of R.A. No. 6539 (the Anti-Carnapping Law).

  2. Whether the penalty of reclusion perpetua was correctly imposed for each case.

  3. Whether the testimonies and credibility of prosecution witnesses were properly evaluated by the trial court.

  4. Whether the trial court correctly awarded damages to the victim's wife.

  5. Is the appellant guilty of carnapping and robbery with homicide?

  6. Is the testimony of the prosecution witness regarding the appellant's confession hearsay?

  7. Is the testimony of the prosecution witness biased?

  8. Should the cash taken from the victim be absorbed in the crime of carnapping?

RULING:

  1. The Court of Appeals affirmed the conviction of appellant for robbery with homicide and carnapping. The Court held that conviction based on circumstantial evidence is sufficient if there is more than one circumstance, the facts from which the inferences are derived are proven, and the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. In this case, the prosecution was able to prove various circumstances that formed an unbroken chain leading to the conclusion that appellant was guilty of the crimes. Therefore, there was sufficient evidence to support his conviction.

  2. The Court modified the penalty imposed for the crime of carnapping. It held that the trial court erred in imposing the penalty of reclusion perpetua for both the crimes of robbery with homicide and carnapping, as the information only alleged that appellant committed the carnapping by means of violence or intimidation against persons and did not allege that the victim was killed in the course of the carnapping. The Court reduced the penalty to an indeterminate sentence of imprisonment of 17 years and four months as minimum to 30 years as maximum for carnapping by means of force and violence upon a person.

  3. The Court found no error in the trial court's evaluation of the testimonies and credibility of prosecution witnesses. It held that the trial court is in the best position to assess the credibility of witnesses, and absent any showing of grave abuse of discretion or arbitrariness, its findings should be accorded great respect.

  4. The Court modified the awards of damages to the victim's wife. It held that the expenses for funeral/burial were not properly substantiated by receipts, except for the payment made to the funeral parlor. The Court also deleted the grant of exemplary damages in the absence of aggravating circumstances. However, it affirmed the award of indemnity, moral damages, and temperate damages.

  5. Yes, the appellant is guilty of carnapping and robbery with homicide. Based on the proven circumstances, the elements of carnapping and robbery with homicide can be reasonably inferred.

  6. No, the appellant's confession to the prosecution witness is not hearsay. Section 33 of Rule 130 of the Rules of Court allows the admission of an accused's declaration acknowledging guilt as evidence against him.

  7. No, there is no evidence to show that the prosecution witness has any motive to testify falsely against the appellant.

  8. No, the cash taken from the victim cannot be absorbed in the crime of carnapping. Carnapping specifically refers to the taking of a motor vehicle and does not cover the taking of cash or personal property that is not a motor vehicle.

PRINCIPLES:

  • 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 is such as to produce a conviction beyond reasonable doubt.

  • Trial courts are in the best position to assess the credibility of witnesses, and their findings should be accorded great respect absent any showing of grave abuse of discretion or arbitrariness.

  • Carnapping is the taking of a motor vehicle belonging to another without consent, using violence, intimidation, or force upon things.

  • Robbery with homicide has elements: (a) taking personal property with violence or intimidation against persons; (b) the property taken belongs to another; (c) there is intent to gain; and (d) homicide is committed as a result of the robbery or on the occasion thereof.

  • A confession by an accused can be admitted as evidence against him, as long as it acknowledges guilt of the offense charged or any offense necessarily included therein.

  • The opportunity to cross-examine a witness negates the claim that the matters testified to by the witness are hearsay.

  • The motive to testify falsely against an accused should be shown to establish bias on the part of the witness.