GR 103272; (July, 1994) (Digest)
G.R. No. 103272 . July 4, 1994.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO ALHAMBRA y MASIGLAT, VIRGILIO DELA CORTA, and RODOLFO AGUIPO y DE LORIA, accused. RENATO ALHAMBRA y MASIGLAT, and VIRGILIO DELA CORTA, accused-appellants.
FACTS
The accused-appellants, Renato Alhambra and Virgilio dela Corta, along with Rodolfo Aguipo, were charged with carnapping under Republic Act No. 6539 . The information alleged that on November 17, 1988, in Manila, they conspired to take, without consent, a 1976 Toyota Corona valued at P70,000.00 belonging to Cesar Pablo. The owner parked and locked his car in front of his house in the evening and discovered it missing the next morning. He promptly reported the loss to the police.
On the same night, a Valenzuela police team, acting on a report of a suspicious vehicle, intercepted a Toyota Corona matching the description. Appellants Alhambra (the driver) and dela Corta, along with Aguipo (a passenger), were inside the car and could not produce any registration documents. The vehicle was impounded. The owner later identified the recovered car as his, noting missing accessories. The three accused were subsequently turned over to the Manila police.
ISSUE
Whether the guilt of accused-appellants Renato Alhambra and Virgilio dela Corta for the crime of carnapping was proven beyond reasonable doubt.
RULING
Yes, but the penalty imposed by the trial court requires modification. The Supreme Court affirmed the conviction but corrected the penalty. The prosecution successfully established the corpus delicti of carnapping through the owner’s testimony of the unlawful taking. Appellants’ possession of the recently stolen vehicle, coupled with their inability to explain such possession, gave rise to a presumption of guilt. Their defenses of denial and alibi were weak and could not prevail over the positive evidence.
The trial court erred in imposing life imprisonment. Under Section 14 of R.A. No. 6539 , the prescribed penalty for carnapping committed without violence, intimidation, or force is imprisonment for not less than fourteen years and eight months and not more than seventeen years and four months. The prosecution did not prove any qualifying circumstances. Therefore, the penalty must be reduced accordingly. The Court modified the judgment to impose an indeterminate penalty of fourteen (14) years and eight (8) months, as minimum, to seventeen (17) years and four (4) months, as maximum. The award of civil indemnity was affirmed.