G.R. No. 139323 ; June 6, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLO ELLASOS Y MAURICIO ALIAS “ROMMEL” and SONNY OBILLO Y GANAYO, accused. SONNY OBILLO Y GANAYO, accused-appellant.

FACTS

Accused Carlo Ellasos and Sonny Obillo were charged with Carnapping with Homicide for the events of April 2, 1992, in San Jose City. The information alleged they conspired to take a motor tricycle owned by Miguel de Belen by means of force and violence, and on the occasion thereof, shot and killed him. Sonny Obillo was arraigned and pleaded not guilty; trial proceeded against him. Carlo Ellasos escaped before arraignment and was arrested four years later, after the prosecution had rested its case against Obillo. The trial court later ordered the separation of their trials. The prosecution presented witnesses including police officers who apprehended the accused, the church caretaker who found them, the victim’s brothers Fernando and Antonio de Belen, the victim’s widow Elena de Belen, and the examining physician Dr. Raul Agliam. Fernando de Belen testified that on the night of April 2, 1992, he saw his brother Miguel in the tricycle with Obillo as passenger and Ellasos driving. Later that night, he saw the same tricycle pass by with only Obillo and Ellasos, and they could not locate Miguel. The next day, Miguel’s body was found tied to a tree. Edgardo Galletes, the church caretaker, testified that he apprehended Obillo and Ellasos in the early morning of April 3, 1992, at an Iglesia ni Cristo compound; Ellasos had a .38 caliber revolver, and Obillo had a tricycle wheel. They were turned over to the police.

ISSUE

The central issue is whether the accused-appellant Sonny Obillo is guilty beyond reasonable doubt of the crime of Carnapping with Homicide.

RULING

The Supreme Court affirmed the conviction of accused-appellant Sonny Obillo for the crime of Carnapping with Homicide. The Court found that the prosecution evidence, particularly the credible and positive testimony of eyewitness Fernando de Belen, established Obillo’s guilt beyond reasonable doubt. Fernando’s testimony placed Obillo at the scene with the victim and Ellasos just before the crime and in the carnapped vehicle without the victim afterward. This, coupled with Obillo’s apprehension with Ellasos shortly after the crime and the recovery of the firearm from Ellasos, sufficiently proved conspiracy between Obillo and Ellasos to commit carnapping and homicide. The Court upheld the trial court’s findings on credibility and rejected Obillo’s defenses. The penalty imposed was reclusion perpetua, and the accused-appellant was ordered to pay civil indemnity, moral damages, and the value of damages to the tricycle to the victim’s heirs.