GR 92167 68; (July, 1995) (Digest)
G.R. Nos. 92167-68 July 14, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE LEGASPI y RAMIREZ, et al., accused-appellants.
FACTS
The accused-appellants were charged under two separate Informations: one for the double murder of Ronaldo Abales and Ariel Heloma, and another for carnapping under R.A. No. 6539 involving a jeepney owned by Jose Abales. The prosecution evidence established that on January 7, 1987, appellant Teody Pamela hired the victims’ jeepney. Later that night, the victims were found hogtied and stabbed to death in Caloocan City. The following morning, the appellants were arrested in San Jose City after a chase, while in possession of the carnapped jeepney. Inside the vehicle, police recovered a bloodied dagger and the driver’s license of Ronaldo Abales. The appellants denied the charges, claiming they were merely passengers invited by co-accused Manuel Torres for a joyride after a drinking session, and alleged coercion during custodial investigation.
ISSUE
Whether the trial court erred in convicting the appellants of the special complex crime of robbery with double homicide based on two separate Informations for murder and carnapping.
RULING
The Supreme Court affirmed the conviction but modified the offense. The trial court erred in convicting appellants of the single, special complex crime of robbery with double homicide. Appellants were charged under two distinct Informations: one for double murder and another for violation of the Anti-Carnapping Act. A joint trial and a consolidated decision do not authorize a conviction for a complex crime not alleged in the Informations. What controls is the description of the crime in the Information. To convict them of a complex crime constitutive of the two separate charges would violate their constitutional right to be informed of the nature and cause of the accusation against them. Therefore, the proper judgment is to find them guilty of two separate crimes. The Court upheld the factual findings of the trial court, rejecting the appellants’ defenses of denial and alibi as weak and unsupported. The circumstantial evidence—their possession of the carnapped vehicle shortly after the murders, the recovery of the blood-stained weapon and the victim’s license from their group, and their conduct—sufficiently established their guilt for both crimes beyond reasonable doubt. The penalty for each crime was imposed separately.