GR 95260; (March, 1996) (Digest)
G.R. No. 95260 March 8, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILFREDO PRADO y CABRERA, accused-appellant
FACTS
On May 12, 1987, tricycle driver Samuel Moulic went missing. His body, bearing multiple stab wounds, was found the next day in San Fabian, Pangasinan. The tricycle he was driving, owned by his brother Jovencio, was also missing. Subsequent investigation revealed that on May 18, 1987, appellant Wilfredo Prado offered to sell a Honda motorcycle with plate number AC-8801 to Edgardo Gomez in La Union. Appellant signed a receipt for a partial payment but could not produce the registration papers. The motorcycle was later confirmed to be the one stolen from the victim. Furthermore, a witness, Elpidio Riveta, identified appellant as the man who hired him to tow a tricycle that had run out of gas on the day of the crime. The tricycle’s sidecar was also found to have been sold by appellant to another person.
ISSUE
The primary issue is whether the circumstantial evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that appellant is guilty of the special complex crime of carnapping with homicide.
RULING
Yes, the Supreme Court affirmed the conviction. The Court meticulously applied the rules on circumstantial evidence, which requires that (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances produces a conviction beyond reasonable doubt. The prosecution successfully established an unbroken chain of circumstances leading to the fair and reasonable conclusion that appellant committed the crime. These include: appellant’s possession and attempt to sell the carnapped motorcycle shortly after the crime; his inability to account for its lawful acquisition; his sale of the tricycle’s sidecar; and his positive identification by Riveta. His defense of merely acting as an agent for the alleged true sellers was correctly rejected by the trial court as not credible, especially since he personally signed the receipt for the partial payment. The crime committed is carnapping with homicide under Section 14 of Republic Act No. 6539 . Since the crime was committed in 1987 when the death penalty was constitutionally prohibited, the proper penalty is reclusion perpetua. The Court affirmed the award of damages and added civil indemnity of P50,000.00 to the victim’s heirs.