GR 116689; (April, 2000) (Digest)
G.R. No. 116689; April 3, 2000
NOLI MARQUEZ, petitioner, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Noli Marquez was charged with violation of the Anti-Carnapping Act (Republic Act No. 6539) for the taking of a Toyota owner-type jeep owned by Sergio Gonzales on September 10, 1990. The jeep was stolen while parked in front of Gonzales’s store. After months of unsuccessful search, Gonzales’s son spotted the vehicle parked in front of an auto supply in March 1991. The police responded and recovered the jeep, inviting Marquez and his co-accused, who were in possession of it, for investigation. The prosecution established that the recovered vehicle, though repainted blue, was the stolen jeep. Gonzales identified it through multiple unique characteristics: a matching spare tire from his bodega, a key that opened the toolbox, specific physical features like the mudguard and steering wheel, and a spare tire holder that fit the jeep’s bolt holes. A PNP crime laboratory examination also revealed that the chassis number had been tampered with and welded over.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt that petitioner Noli Marquez committed the crime of carnapping.
RULING
The Supreme Court affirmed the conviction. The ruling hinges on the application of the doctrine of recent possession of stolen property. The Court found that the jeep in Marquez’s possession was conclusively proven to be the same vehicle stolen from Gonzales. The detailed and unrebutted testimonial and object evidence—ranging from the owner’s positive identification based on unique parts and accessories to the forensic finding of a tampered chassis number—solidly established the corpus delicti of carnapping. Possession of the recently stolen vehicle created a presumption of guilt, placing the burden on the petitioner to explain his lawful acquisition. Marquez failed to provide a credible and satisfactory explanation for his possession. His claim of purchasing the jeep from another party was deemed insufficient to overturn the presumption arising from recent, unexplained possession of stolen property. Consequently, his guilt for violating the Anti-Carnapping Act was sustained beyond reasonable doubt.