G.R. No. 119495 April 15, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCISCO FERRAS y VERANCES, JESSIE FERRAS y VERANCES, LOUIE LIMUECO y DE GUZMAN and TEDDY MACANAS, defendants, FRANCISCO FERRAS y VERANCES, defendant-appellant.

FACTS

On March 9, 1993, in Cabanatuan City, a motorized tricycle owned by Romeo Sarengo and driven by his brother, Edwin Sarengo, was carnapped, and Edwin was killed. SPO3 Romeo Turqueza led a police team in hot pursuit. In Sto. Tomas, Aliaga, Nueva Ecija, they found the described tricycle parked at a vulcanizing shop. Four persons fled upon the police’s arrival. The police apprehended Louie Limueco, who was wearing an orange T-shirt matching a description of a carnapper. Upon interrogation, Limueco identified his companions. The police subsequently apprehended the Ferras brothers, Francisco and Jessie, in an uninhabited house nearby. A .38 caliber paltik, three empty shells, and one live ammunition were found on Jessie Ferras, who admitted to the crime. Accused Teddy Macanas remained at large. Francisco Ferras and Louie Limueco pleaded not guilty and claimed they were in Sta. Rosa, Nueva Ecija, to hire a jeepney for carnival equipment when they were invited by Jessie Ferras and Teddy Macanas for a ride. They testified that the tricycle had a flat tire, and while at a vulcanizing shop, the police arrived, causing Jessie and Macanas to flee. They denied knowledge of the carnapping. The Regional Trial Court convicted Francisco Ferras and Louie Limueco of carnapping under the Anti-Carnapping Act and sentenced them to life imprisonment. Only Francisco Ferras appealed.

ISSUE

Whether the guilt of appellant Francisco Ferras for the crime of carnapping has been proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Francisco Ferras and Louie Limueco. The prosecution’s evidence, primarily the testimony of SPO3 Turqueza, was circumstantial and insufficient to prove guilt beyond reasonable doubt. The circumstances presented—that appellant was found 350 meters from the carnapped tricycle, that he fled, and that he was identified by his co-accused—did not constitute an unbroken chain leading to the fair and reasonable conclusion that he was a participant in the carnapping. Flight alone is not proof of guilt. The identification by co-accused Louie Limueco was deemed unreliable as it was given while under police custody and was not corroborated. The prosecution failed to present any eyewitness to the actual carnapping or to establish conspiracy. The defense of being an innocent companion was credible and consistent. The Court also ordered the acquittal of co-accused Louie Limueco, as the judgment was favorable and applicable to him, and directed the arrest of the remaining accused, Teddy Macanas.