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PEOPLE v. JESUSANO ARCENAL Y AGUILAN

FACTS:

Jesusano Arcenal was charged with violation of the Anti-Carnapping Act of 1972 for unlawfully taking and driving away a motorized tricycle owned by Renato de Rama in the Municipality of Pila, Province of Laguna. During the commission of the offense, Arcenal attacked and struck the driver of the tricycle, causing his death. Arcenal pleaded not guilty to the charges. The prosecution presented witnesses who testified that Arcenal was seen driving the tricycle alone after the victim was last seen with him. The victim's body was found with multiple wounds, and the autopsy revealed that he died of shock due to intra-cranial hemorrhage caused by trauma. The defense presented a different set of events, claiming that Arcenal was in Barangay Aplaya, Pila, Laguna on the date of the incident to visit his sick relative. He denied any involvement in the carnapping and killing of the victim.

Arcenal was convicted by the Regional Trial Court (RTC) based on the uncontroverted presence of his fingerprint on the tricycle, which established that he took possession of the vehicle. The court rejected Arcenal's defense of denial and alibi due to lack of corroboration and consistency. It also considered Arcenal's failure to visit his parents and siblings in Pila since 2000 as an indication of a fear of arrest and criminal liability. The Court of Appeals (CA) affirmed the RTC's decision, finding that the circumstantial evidence pointed to Arcenal's guilt.

The main issue before the court is whether the prosecution has proven beyond reasonable doubt that Arcenal is guilty of the crime of carnapping with homicide. The court explains that for this crime to be established, there must be proof of the essential elements of carnapping, and the killing must have been part of the original criminal design or committed during the commission of carnapping. Although there were no eyewitnesses to the killing, the court finds that the combination of circumstantial evidence presented establishes Arcenal's guilt beyond reasonable doubt.

ISSUES:

  1. Whether the pieces of circumstantial evidence presented establish the guilt of the accused beyond reasonable doubt.

  2. Whether the accused can be convicted based on circumstantial evidence.

  3. Whether there was unlawful taking of the vehicle.

  4. Whether the accused had the intent to gain.

  5. Whether the accused had the intent to gain and committed carnapping and murder

  6. Whether the defense of alibi is credible

  7. Whether the accused-appellant is guilty of the crime of Carnapping with homicide.

  8. Whether the penalty of reclusion perpetua is correct in this case.

RULING:

  1. Yes, the pieces of circumstantial evidence presented establish the guilt of the accused beyond reasonable doubt. The combination of circumstances, which are consistent with each other, leaves no reasonable doubt as to the guilt of the accused. Circumstantial evidence, if sufficient, can replace direct evidence to warrant the conviction of an accused.

  2. Yes, the accused can be convicted based on circumstantial evidence. To justify a conviction based on circumstantial evidence, there must be more than one circumstance, the facts from which the inferences are derived have been proven, and the combination of all these circumstances results in a moral certainty that the accused is the one who committed the crime.

  3. Yes, there was unlawful taking of the vehicle. Unlawful taking is complete from the moment the offender gains possession of the thing. The prosecution was able to prove that there was unlawful taking of the vehicle.

  4. Yes, the accused had the intent to gain. Intent to gain is presumed from the unlawful taking of the vehicle. The fingerprints found on the vehicle, which were confirmed as identical to the accused's, establish that he had possession of the vehicle.

  5. Yes, the accused had the intent to gain and committed carnapping and murder. The internal act of intent to gain is presumed from the unlawful taking of the motor vehicle, regardless of actual gain. The accused fleeing with the tricycle showed his intent to gain. The evidence presented, such as the wounds on the victim's head, the accused being the back rider passenger, and the bloodstains on the tricycle, established that the assault happened while the victim was in the vehicle or within its vicinity. Thus, the accused is guilty of carnapping and killing the victim.

  6. No, the defense of alibi is not credible. Alibi is the weakest of all defenses and the accused failed to establish the physical impossibility for him to be at the scene of the crime. The accused did not present any evidence or testimony to corroborate his alibi. On the other hand, the prosecution ascertained the accused's identity as the perpetrator based on positive identification by witnesses. The testimonies of the witnesses, along with other circumstances, sufficiently establish the accused's identity as the author of the crime to the exclusion of all others.

  7. The Court affirmed the lower court's finding that the accused-appellant is guilty beyond reasonable doubt of the crime of Carnapping with homicide. There is no cogent reason to doubt the veracity of the findings and conclusions made by the trial court on the credibility of the prosecution witnesses' testimonies.

  8. The Court upheld the imposition of the penalty of reclusion perpetua. No aggravating circumstances were proven that would warrant the imposition of the penalty of death. The court also ordered the accused-appellant to pay the heirs of the victim civil indemnity, moral damages, exemplary damages, and temperate damages, plus interest at the legal rate of six percent (6%) per annum from the date of finality of the decision.

PRINCIPLES:

  • Circumstantial, indirect, or presumptive evidence, if sufficient, can replace direct evidence to warrant the conviction of an accused. The combination of circumstances must be interwoven in such a way as to leave no reasonable doubt as to the guilt of the accused.

  • Unlawful taking is the taking of a motor vehicle without the owner's consent, by means of violence or intimidation, or by using force upon things. It is deemed complete from the moment the offender gains possession of the vehicle.

  • Intent to gain, or the animus lucrandi, is presumed from the unlawful taking of the vehicle.

  • Intent to gain, or animus lucrandi, is presumed from the unlawful taking of a motor vehicle. Actual gain is irrelevant.

  • Gain extends beyond pecuniary benefit and includes any other benefit derived or expected from the act.

  • Flight is an indication of guilt or a guilty mind.

  • Alibi is the weakest of all defenses and must be supported by credible corroboration from disinterested witnesses.

  • Positive identification pertains to proof of identity and not necessarily being an eyewitness to the act of the crime. It can be based on the suspect or accused being the person last seen with the victim before and after the crime.

  • Trivial inconsistencies in testimonies do not affect the essential elements of the crime and do not discredit the witnesses. The trial court's assessment of witness credibility deserves high respect.

  • In cases of special complex crimes like carnapping with homicide, the imposable penalty is reclusion perpetua.

  • The amounts of civil indemnity, moral damages, and exemplary damages in cases of special complex crimes like carnapping with homicide are set at P75,000.00 each.

  • Temperate damages may be awarded when the amount of actual damages cannot be proved with certainty, and it is shown that the victim suffered pecuniary loss but the exact amount cannot be determined.

  • Interest on damages awarded shall be at the legal rate of six percent (6%) per annum from the date of finality of the decision.