GR 132788; (October, 2003) (Digest)
G.R. No. 132788; October 23, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ISAIAS FERNANDEZ y VERAS a.k.a. “ISAIAH FERNANDEZ,” appellant.
FACTS
On April 21, 1996, Clifford Guinguino, the driver of a maroon Tamaraw FX taxi owned by Engineer Jeffred Acop, was last seen alive driving his vehicle with four or five male passengers in Baguio City. The following morning, his body, bearing multiple gunshot wounds, was discovered. The taxi was missing. Appellant Isaias Fernandez was later arrested. The prosecution’s case rested largely on circumstantial evidence, including the testimony of Laurencio Ducusin, a barangay captain from Pangasinan. Ducusin testified that in late April 1996, Fernandez, whom he knew, arrived at his house driving a maroon Tamaraw FX. Fernandez offered to sell him the vehicle for a suspiciously low price, claiming it was “hot.” Ducusin refused and later reported the incident to the police after learning about the Baguio carnapping.
ISSUE
Whether the circumstantial evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that appellant Isaias Fernandez is guilty of carnapping with homicide.
RULING
Yes. The Supreme Court affirmed the conviction. The legal logic hinges on the sufficiency of circumstantial evidence under Section 4, Rule 133 of the Rules of Court. The Court meticulously examined the established circumstances: (1) the carnapping and killing of Guinguino occurred; (2) shortly thereafter, Fernandez was found in possession of the carnapped vehicle in another province; (3) he attempted to sell it at an abnormally low price; and (4) he explicitly admitted the vehicle was “hot,” indicating knowledge it was stolen. These facts constitute an unbroken chain leading to the reasonable and moral certainty that Fernandez was the author of the crime. The doctrine of recent unexplained possession of stolen property applies; Fernandez’s failure to provide a credible explanation for his possession of the recently stolen taxi justified the inference that he was the carnapper. The combination of all these circumstances produced a conviction beyond reasonable doubt. The penalty was reduced to reclusion perpetua, as the requisite qualifying circumstance for the death penalty—that the killing occurred “in the course of the commission of the carnapping or on the occasion thereof”—was not alleged with specificity in the Information.