G.R. No. 196005 October 1, 2014
PEOPLE OF THE PHILIPPINES, Appellee, vs. CHARLIE FIELDAD, RYAN CORNISTA, and EDGAR PIMENTEL, Appellants.

FACTS

Appellants Charlie Fieldad, Ryan Cornista, and Edgar Pimentel, along with other inmates, were charged with two counts of Murder for the killing of jail guards JO2 Reynaldo Gamboa and JO1 Juan Bacolor, Jr., and with Carnapping, all occurring on March 9, 1999, inside the BJMP Compound in Urdaneta City, Pangasinan. The prosecution’s evidence, primarily from eyewitness JO2 Marlon Niturada, established that during a jailbreak, Julius Chan shot JO2 Gamboa. Appellants Fieldad and Cornista then grappled with JO1 Bacolor for his armalite; Cornista struck Bacolor, and Fieldad shot him twice with Gamboa’s gun. Florante Leal took the armalite and shot at Niturada. The inmates, including appellants, then escaped. Outside the compound, Fieldad, Leal, Cornista, and Pimentel, along with others, commandeered a Tamaraw jeep without the owner’s consent to flee. They were later arrested after the vehicle they transferred to met an accident. Appellants denied liability, claiming they were forced at gunpoint by Leal to participate in the escape. The Regional Trial Court convicted appellants of Murder and Carnapping. The Court of Appeals affirmed the convictions but modified the penalties and damages.

ISSUE

The core issue is whether the guilt of appellants Charlie Fieldad, Ryan Cornista, and Edgar Pimentel for the crimes of Murder and Carnapping was proven beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATIONS.
1. On the Murder Charges: The Court found the appellants guilty of Murder qualified by treachery for the deaths of JO2 Gamboa and JO1 Bacolor. The attack was sudden and unexpected, ensuring the execution of the crime without risk to the assailants. The Court upheld the finding of conspiracy among the inmates, including appellants, based on their collective and concerted actions before, during, and after the killings and escape. Appellants’ defenses of denial and compulsion were rejected. The Court found no evidence that they acted under uncontrollable fear of an equal or greater injury, as they failed to report the alleged threats after their arrest.
2. On the Carnapping Charge: The Court affirmed the conviction for Carnapping. The elements were present: appellants took a Tamaraw jeep belonging to Benjamin Bauzon without his consent, and the taking was committed with the use of an unlicensed firearm (the armalite used by Leal during the escape). Their claim of being forced to drive or ride the vehicle did not negate criminal liability.
3. On Penalties and Damages: The penalty for each count of Murder is reclusion perpetua, without eligibility for parole. For Carnapping, the penalty is imprisonment for not less than 20 years and 1 day to 30 years (reclusion temporal). The Court increased the awards for civil indemnity, moral damages, and exemplary damages for each murder to Php75,000.00, Php50,000.00, and Php30,000.00, respectively, with 6% interest per annum from finality until full payment. Actual damages were deleted for lack of substantiation, but temperate damages of Php25,000.00 were awarded for each murder. Loss of earning capacity was upheld. For Carnapping, the value of the vehicle (Php80,000.00) was ordered returned to the owner or its value paid as civil liability.