G.R. No. 226846, June 21, 2017
People of the Philippines, Plaintiff-Appellee vs. Jeffrey Macaranas y Fernandez, Accused-Appellant

FACTS

On February 18, 2007, Frank Karim Langaman and his girlfriend Kathlyn Cervantes were in Meycauayan, Bulacan, on Frank’s motorcycle. Three men approached them. One man shot Frank in the neck, demanded and took Kathlyn’s cellphone, and hit her. While this occurred, a second man took the motorcycle, and the third man, accused-appellant Jeffrey Macaranas, stood guard as a look-out. The three men then fled together on the stolen motorcycle. Frank later died from his injuries. An Information was filed charging Macaranas and others with Carnapping under Republic Act No. 6539 (The Anti-Carnapping Act), alleging the taking of the motorcycle by means of violence and intimidation, and that the killing of Frank was committed on the occasion thereof.
During trial, the prosecution presented eyewitness Kathlyn Cervantes, who identified Macaranas as the look-out. The defense presented Macaranas, who denied involvement, claiming he was elsewhere and was later coerced by barangay officials into implicating his cousin. The Regional Trial Court found Macaranas guilty beyond reasonable doubt of Carnapping and sentenced him to Reclusion Perpetua, with damages. The Court of Appeals affirmed the conviction but modified the awarded damages.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Jeffrey Macaranas for the crime of Carnapping under Republic Act No. 6539.

RULING

The Supreme Court denied the appeal and affirmed the modified decision of the Court of Appeals. The legal logic rests on the establishment of conspiracy and the proper application of the penalty for carnapping with homicide. The prosecution successfully proved all elements of carnapping: the taking of a motorcycle belonging to another, without consent, and with intent to gain, accomplished by means of violence against persons. Eyewitness testimony positively identified Macaranas as a conspirator who acted as a look-out during the commission of the crime. In conspiracy, the act of one is the act of all; thus, Macaranas is equally liable for the acts of his co-accused, including the killing.
The Court upheld the penalty of Reclusion Perpetua, as prescribed by Section 14 of R.A. No. 6539, which mandates this penalty when the carnapping is committed with violence against or intimidation of any person, or when the owner, driver, or occupant is killed or raped in the course of the commission of the crime. The Court found no merit in the defense of denial and alibi, which cannot prevail over the positive and credible identification by the eyewitness. The award of damages was correctly modified by the appellate court in accordance with prevailing jurisprudence.