G.R. No. 187044 ; September 14, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RENATO LAGAT Y GAWAN A.K.A. RENAT GAWAN AND JAMES PALALAY Y VILLAROSA, Accused-Appellants.

FACTS

Accused-appellants Renato Lagat and James Palalay were charged with Qualified Carnapping under Republic Act No. 6539 . The Information alleged that on or about April 12, 2005, in Santiago City, they conspired to take, steal, and carry away a tricycle owned and driven by Jose Biag, valued at ₱70,000.00, without his consent and with intent to gain. In the course of the carnapping, they assaulted, attacked, and wounded Biag with a sharp instrument, inflicting multiple stab and hacking wounds that caused his death.
Lagat pleaded not guilty at arraignment; a plea of not guilty was entered for Palalay. Their plea-bargaining proposal to plead guilty to Homicide was rejected by the prosecution. Pre-trial admissions established that: 1) Biag’s cadaver was recovered along Angadanan and San Guillermo road by police and barangay officials; 2) the two accused were arrested in possession of allegedly stolen palay in Alicia, Isabela; and 3) the cause of death was multiple stab and hack wounds.
At trial, the prosecution presented the victim’s wife, Florida Biag, who testified about her husband’s disappearance, the recovery of his tricycle and body, and the expenses and income loss incurred. Barangay Tanod Poe Rumbaoa, Sr. testified to identifying Biag’s body and learning from police that the tricycle was used in a palay theft. PO2 Arthur Salvador testified that upon a report of stolen palay, they found the accused with the tricycle and palay at a buying station; the accused fled but were apprehended. At the police station, bloodstains were found on the tricycle, and Biag’s registration documents were recovered. PO2 Salvador claimed that, after being informed of their constitutional rights, the accused voluntarily admitted they killed Biag and dumped his body when they carnapped the tricycle. The body was subsequently found at the indicated location. PO2 Bernard Ignacio corroborated this testimony, adding that the accused narrated how they rented the tricycle, poked a knife at the driver, chased, and stabbed him. PO2 Ignacio admitted the accused were not assisted by counsel during custodial investigation. A Post-Mortem Autopsy Report indicated Biag died from multiple wounds.
The accused filed a Motion to Dismiss on Demurrer to Evidence without leave of court, arguing the prosecution failed to prove guilt beyond reasonable doubt and that their constitutional rights during custodial investigation were violated. The trial court denied the motion and, as the accused did not present evidence, considered the case submitted for decision.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellants for Qualified Carnapping.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that all elements of Qualified Carnapping were proven beyond reasonable doubt: 1) the accused took the motor vehicle; 2) the vehicle belonged to another; 3) the taking was without the owner’s consent; 4) it was done with intent to gain; and 5) the owner, driver, or occupant was killed or raped in the course of the carnapping. The accused were found in possession of the recently carnapped tricycle, which had bloodstains and contained the victim’s documents. Their flight upon seeing the police was indicative of guilt. The detailed autopsy report corroborated the violent death. The killing was integral to the carnapping, as it was committed to facilitate the taking of the vehicle or to escape.
The Court ruled that the extrajudicial confessions/admissions made during custodial investigation without counsel were inadmissible, in line with constitutional safeguards. However, the conviction was sustained based on the totality of other credible evidence, which constituted an unbroken chain leading to the conclusion that the accused were the perpetrators. The denial of the Demurrer to Evidence was proper as the prosecution evidence, if unrebutted, was sufficient to support a conviction. The mitigating circumstance of plea of guilty was not applicable as their plea-bargain was rejected, and they did not plead guilty to the offense charged. The award of damages was modified in accordance with prevailing jurisprudence.