GR 216015; (March, 2017) (Digest)
G.R. No. 216015. March 27, 2017.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JESUSANO ARCENAL Y AGUILAN, ACCUSED-APPELLANT.
FACTS
Accused-appellant Jesusano Arcenal was charged with Carnapping with Homicide under Republic Act No. 6539, as amended. The prosecution established that on April 11, 2000, in Pila, Laguna, tricycle driver Alvin de Rama was last seen alive with Arcenal as his lone passenger. Shortly after they left the terminal, a witness saw Arcenal driving the victim’s tricycle alone at high speed. Alvin’s body, bearing severe head wounds, was discovered the next morning. The carnapped tricycle, with bloodstains, was later recovered in a different town. The autopsy concluded the cause of death was shock secondary to intracranial hemorrhage from trauma.
The defense presented an alibi, claiming Arcenal was in a different barangay on the night of the crime and had subsequently moved to Batangas, only returning to Laguna years later, where he was arrested. The Regional Trial Court convicted Arcenal and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction, prompting this appeal.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of accused-appellant Jesusano Arcenal for the crime of Carnapping with Homicide.
RULING
The Supreme Court affirmed the conviction. The prosecution successfully proved Arcenal’s guilt beyond reasonable doubt through a combination of credible circumstantial evidence. The established facts—that Arcenal was the last person seen with the victim, was seen driving the victim’s tricycle alone shortly after, fled the locality immediately after the incident, and was positively identified by a witness—formed an unbroken chain leading to the reasonable conclusion that he was the perpetrator. The Court emphasized that circumstantial evidence is sufficient for conviction if it leads to a conviction that is consistent with all the proven facts and excludes every other reasonable hypothesis of innocence.
The defense of alibi was correctly rejected for being inherently weak and unsubstantiated by clear and convincing proof. It could not prevail over the positive circumstantial evidence presented by the prosecution. The Court modified the awarded damages, increasing civil indemnity, moral damages, and exemplary damages to P75,000.00 each and awarding P50,000.00 as temperate damages, all with legal interest. The penalty of reclusion perpetua was affirmed.