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PEOPLE v. FABIAN URZAIS Y LANURIAS

FACTS:

The case involves accused-appellant Fabian Urzais y Lanurias who, along with co-accused Alex Bautista and Ricky Bautista, was charged with the violation of the Anti-Carnapping Act of 1972, as amended, and homicide through the use of an unlicensed firearm. According to the Information filed, on or about November 13, 2002, in Cabanatuan City, the accused, acting in conspiracy, forcefully took a Isuzu Highlander car owned by Mario Magdato with a value of 500,000 pesos. They assaulted Mario Magdato during the carnapping by shooting him with an unlicensed firearm, causing his death. The accused-appellant pleaded not guilty to the charges and the trial proceeded. The prosecution presented witnesses who testified about the circumstances surrounding the arrest of the accused, the discovery of the victim's body, and the cause of his death. The accused denied the charges and claimed that he had ordered an owner-type jeepney from the co-accused but was surprised when they delivered a green Isuzu Highlander instead.

The accused, Fabian Urzais alias Michael Tapayan, was found guilty by the Regional Trial Court (RTC) of the crime of carnapping and homicide through the use of an unlicensed firearm. The court based its ruling on the disputable presumption that a person found in possession of a thing taken in the doing of a recent wrongful act is the taker and the doer of the whole act. The accused allegedly purchased a Isuzu Highlander for a low price from his friends in Bulacan, and upon advice from a friend that it might be a "hot car," he decided to sell the vehicle. However, he was arrested by a member of the Criminal Investigation and Detection Group (CIDG) of Sta. Rosa, Nueva Ecija. The accused claimed that he found out in jail that the owner of the vehicle had died. The RTC sentenced the accused to imprisonment for forty (40) years of reclusion perpetua and ordered him to indemnify the heirs of the victim. The Court of Appeals affirmed the decision of the RTC. The accused appealed his conviction, arguing that there was no direct evidence linking him to the crime and that the circumstantial evidence of his possession of the allegedly carnapped vehicle is insufficient to prove his guilt. The Supreme Court agreed with the accused and acquitted him, stating that the prosecution failed to prove both the fact of the crime and the accused's involvement beyond reasonable doubt. The Court noted that the disputable presumption created by law that a person in possession of a recently stolen object is the perpetrator of the crime does not hold in this case.

The case involves a challenge to the constitutionality of Section 14 of the Anti-Carnapping Act, particularly the provision that imposes the penalty of reclusion perpetua to death when the owner, driver, or occupant of the carnapped motor vehicle is killed or raped in the course of the commission of the carnapping or on the occasion thereof. The said provision has undergone three amendments: (1) changing the penalty of life imprisonment to reclusion perpetua, (2) including rape as an additional element, and (3) clarifying that the offense is a special complex crime, similar to robbery with violence against or intimidation of persons under the Revised Penal Code.

ISSUES:

  1. Whether the charge of carnapping against the accused-appellant is substantiated by the evidence presented.

  2. Whether the circumstantial evidence of possession of the allegedly carnapped vehicle is sufficient to sustain a conviction for the special complex crime.

  3. Whether the accused-appellant should be convicted of the special complex crime of carnapping with homicide/murder.

  4. Whether the prosecution was able to prove the guilt of the accused-appellant beyond reasonable doubt.

  5. Whether the disputable presumption on the accused's possession of the missing vehicle can prevail over his explanation for such possession

  6. Whether the accused's guilt was established beyond reasonable doubt

RULING:

  1. The charge of carnapping against the accused-appellant is not substantiated by the evidence presented. The prosecution failed to prove all the elements of carnapping, and there is no direct evidence indicating the guilt of the accused-appellant. The prosecution's evidence only consists of the victim's disappearance, the discovery of his death, and the details surrounding accused-appellant's arrest on rumors that the vehicle he possessed had been carnapped. There is no evidence supporting the theory that the vehicle had been carnapped or that accused-appellant is the author of the same.

  2. The circumstantial evidence of possession of the allegedly carnapped vehicle is not sufficient to sustain a conviction for the special complex crime. There is only one circumstantial evidence, and it does not lead to an inference exclusively consistent with guilt. The prosecution did not provide any evidence detailing the seizure of the vehicle or accused-appellant's participation. Additionally, there is a variance in the evidence regarding how accused-appellant was discovered to be in possession of the vehicle. The sole circumstantial evidence does not constitute an unbroken chain leading to one fair and reasonable conclusion pointing to accused-appellant as the guilty person.

  3. The accused-appellant should not be convicted of the special complex crime of carnapping with homicide/murder. While there is guilt in the acquisition of the vehicle at a suspiciously low price, the prosecution failed to prove that the accused-appellant was involved in the carnapping and the homicide/murder of the owner. The evidence shows that the accused-appellant's crime, if any, was being in possession of a missing vehicle whose owner had been found dead.

  4. The prosecution was unable to prove the guilt of the accused-appellant beyond reasonable doubt. The accused-appellant set up a defense of denial and provided an explanation for his possession of the vehicle, stating that he purchased it from the brothers Alex and Ricky Bautista. The prosecution failed to produce evidence that would render the defense of the accused-appellant improbable.

  5. The disputable presumption cannot prevail over the accused's explanation for his possession of the missing vehicle. The possession was explained, thus disputing the legal presumption. Holding otherwise would lead to a miscarriage of justice.

  6. The guilt of the accused was not established beyond reasonable doubt. There were no eyewitnesses to the killing of the victim, and the courts relied only on circumstantial evidence. No connection was established between the victim's death and the firearm found in the possession of the accused. The equipoise rule applies, and the evidence does not support a conviction.

PRINCIPLES:

  • In order for circumstantial evidence to sustain a conviction, there must be more than one circumstance, the facts from which the inferences are derived must be proven, and the combination of all the circumstances must produce a conviction beyond reasonable doubt. The circumstantial evidence must constitute an unbroken chain leading to one fair and reasonable conclusion pointing to the accused as the guilty person, to the exclusion of all others. (Reiterated from decided cases)

  • The prosecution has the burden of proving all the elements of the offense charged beyond reasonable doubt. If the elements of carnapping are not proved, the provisions of the Anti-Carnapping Act would not be applicable, and the homicide or murder (if proven) would be punishable under the Revised Penal Code.

  • The disputable presumption in Section 3 (j), Rule 131 of the Rules of Court, that a person found in possession of a thing taken in the doing of a recent wrongful act is the taker and doer of the whole act is limited to cases where such possession is either unexplained or that the proffered explanation is rendered implausible in view of independent evidence inconsistent thereto.

  • Once an explanation is made for the possession of a thing taken in the doing of a recent wrongful act, the presumption arising from the unexplained possession may no longer be invoked. The burden then shifts to the prosecution to produce evidence that would render the defense of the accused improbable.

  • Criminal convictions require proof of guilt beyond reasonable doubt and should not solely be based on legal presumptions.

  • The equipoise rule tilts the scales in favor of the accused when the evidence is evenly balanced.

  • The prosecution has the burden of proving guilt beyond reasonable doubt, and acquittal is the constitutional duty of the court when this burden is not met.