G.R. No. 212815 March 1, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs ENRILE DONIO y UNTALAN, Accused-Appellant

FACTS

Accused-appellant Enrile Donio was charged with carnapping with homicide under R.A. No. 6539, as amended. The Information alleged that on November 26, 2003, in Mabalacat, Pampanga, Donio, together with two others at-large, took a Honda TMX 155 tricycle owned and driven by Raul Layug, and killed Layug on the occasion thereof using a mini jungle bolo. The prosecution established that in the early morning of November 26, police manning a checkpoint in Concepcion, Tarlac, stopped a speeding tricycle driven by Donio. He presented a temporary license under the name “Raul Layug” but could not produce the vehicle’s registration. A visual search revealed a bloodstained mini jungle bolo inside the tricycle. The vehicle was seized and its occupants, including Donio, were brought to the police station. Donio later asked permission to retrieve the registration papers but never returned. That same morning, the victim’s brothers discovered Raul Layug’s body and later identified the impounded tricycle as their own.
The defense presented Donio as its sole witness. He denied the accusation, claiming he was at home tending to his sick child from the evening of November 25 until the next day. He alleged he was a sugarcane plantation worker who did not leave his workplace for months and that he only learned of the charge when police came looking for his co-accused. He testified that he was tortured into admitting the crime.

ISSUE

Whether the prosecution proved the guilt of accused-appellant Enrile Donio for the crime of carnapping with homicide beyond reasonable doubt.

RULING

No. The Supreme Court acquitted Donio, finding that the prosecution failed to prove his guilt beyond reasonable doubt. The Court emphasized that in criminal cases, the burden of proof lies with the prosecution, which must rely on the strength of its own evidence and not on the weakness of the defense. The core of the prosecution’s case was the alleged warrantless arrest and seizure of the tricycle and bolo from Donio at the checkpoint. However, the Court found the checkpoint operation irregular. The police testified they were stopping vehicles to issue cards as part of a campaign against hijacking, but there was no evidence of a specific ongoing incident that would justify the invasive search. The discovery of the bolo was not inadvertent but the result of a visual search conducted without a warrant and without Donio’s consent, absent any lawful arrest. Consequently, the tricycle and the bolo, being products of an unlawful search, are inadmissible as evidence under the exclusionary rule.
Furthermore, the prosecution failed to establish the identity of the tricycle’s driver as the perpetrator of the killing. No witness directly identified Donio as the one who killed Raul Layug. The circumstantial evidence presented did not constitute an unbroken chain leading to the conclusion that Donio was guilty of carnapping with homicide. The positive identification of the vehicle did not equate to the positive identification of the killer. The defense of alibi, while generally weak, was not entirely baseless and, coupled with the prosecution’s failure to meet its burden, created reasonable doubt. The Court reversed the decisions of the lower courts and ordered Donio’s immediate release.