G.R. No. 207662. April 13, 2016.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. FABIAN URZAIS Y LANURIAS, ALEX BAUTISTA, AND RICKY BAUTISTA, ACCUSED. FABIAN URZAIS Y LANURIAS, ACCUSED-APPELLANT.

FACTS

Accused-appellant Fabian Urzais y Lanurias, together with co-accused Alex Bautista and Ricky Bautista (at large), was charged with carnapping with homicide through the use of an unlicensed firearm under Republic Act No. 6539, as amended. The Information alleged that on or about November 13, 2002, in Cabanatuan City, they conspired to carnap a green Isuzu Highlander owned by Mario Magdato and, on the occasion thereof, shot and killed him with an unlicensed firearm. Accused-appellant pleaded not guilty.
The prosecution established that on November 12, 2002, victim Mario Magdato left with his vehicle for work and did not return. His body was later discovered with a fatal gunshot wound. On November 20, 2002, police, acting on a flash alarm, apprehended accused-appellant while he was driving the carnapped vehicle. A Norinco 9mm pistol was found tucked in his waist. The vehicle had bloodstains and its engine number matched the victim’s. Accused-appellant interposed the defense of denial, claiming he purchased the vehicle for a low price from the Bautista brothers, unaware it was carnapped, and was attempting to surrender or sell it when arrested.
The Regional Trial Court convicted accused-appellant, applying the presumption under Rule 131, Section 3(j) of the Rules of Court that a person found in possession of a thing taken in a recent wrongful act is the taker. The Court of Appeals affirmed the conviction with modification. Accused-appellant appealed to the Supreme Court.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellant is guilty of the crime of carnapping with homicide.

RULING

No. The Supreme Court REVERSED and SET ASIDE the Decision of the Court of Appeals and ACQUITTED accused-appellant Fabian Urzais y Lanurias on reasonable doubt.
The Court held that the prosecution failed to prove the two requisite facts for a criminal conviction: (1) the fact of the crime, and (2) the fact that the accused is the perpetrator. For carnapping with homicide, the prosecution must prove the elements of carnapping and that the killing was committed during or on the occasion of the carnapping. The Court found the evidence insufficient.
The sole circumstantial evidence was accused-appellant’s possession of the carnapped vehicle one week after the incident. This alone does not satisfy the requirements for conviction based on circumstantial evidence under Rule 133, Section 4 of the Rules of Court, which demands more than one circumstance, facts from which the inferences are derived are proven, and the combination of all circumstances produces a conviction beyond reasonable doubt. The prosecution did not present evidence directly linking accused-appellant to the killing or showing his participation in the carnapping itself. The presumption under Rule 131, Section 3(j) is disputable and cannot prevail over the constitutional presumption of innocence. The defense’s claim of being an innocent purchaser, though questionable, introduced reasonable doubt. The Court emphasized that suspicion alone is not sufficient for conviction. The acquittal is without prejudice to any investigation for the crime of fencing under Presidential Decree No. 1612.