G.R. No. 83798 March 29, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO DE LA CRUZ y RUADO, ROMEO SALVADOR y MENDOZA, DANTES BELOSO y DE CASTRO, defendants-appellants.

FACTS

The case involves the carnapping of a Ford Telstar on December 5, 1984, and the killing of its owner, Anthony Banzon. Appellants Dantes Beloso and Romeo Salvador, along with Danilo de la Cruz (who withdrew his appeal), were convicted of Carnapping with Homicide. The prosecution established that Beloso placed a newspaper advertisement to buy a car, to which Banzon responded. Banzon and his mother met Beloso at an office. Later, Banzon went with De la Cruz to the latter’s house, where Salvador was present. Salvador, in his sworn statement, recounted hearing a gunshot and later seeing Banzon dead and De la Cruz holding a gun. Beloso and Salvador later drove away in the carnapped vehicle. Both appellants gave extrajudicial confessions detailing their roles but later recanted, claiming the confessions were coerced.

ISSUE

The core issue is whether the extrajudicial confessions of Beloso and Salvador are admissible and sufficient, alongside other evidence, to sustain their conviction for Carnapping with Homicide beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the validity and corroboration of the extrajudicial confessions. The Court rejected the claims of coercion, noting the confessions were executed before responsible government officers, contained erasures countersigned by Beloso indicating voluntariness, and were witnessed by a police reporter whose presence negated any covert maltreatment. These confessions were deemed admissible as they were given freely and intelligently. Furthermore, the confessions were corroborated by other evidence, such as the paraffin tests positive for gunpowder on both appellants and the established fact of the carnapping and homicide. The Court applied Section 14 of Republic Act No. 6539 (Anti-Carnapping Act), which prescribes the penalty of life imprisonment to death when the owner is killed during the carnapping. The trial court correctly imposed reclusion perpetua following the constitutional prohibition on the death penalty. The conspiracy was evident from the coordinated actions: Beloso lured the victim via the advertisement, De la Cruz executed the killing at his house where Salvador was present, and Beloso and Salvador then took possession of the vehicle. Their collective actions demonstrated a unified purpose to commit the crime.