People v. Mallari
REITERATIONFacts
The Antecedents: An Information was filed charging Reynaldo Mallari and co-accused with carnapping with homicide for the unlawful taking of a Toyota Tamaraw FX, valued at ₱300,000.00, belonging to Lourdes Eleccion, during which the driver, Erico Medel, was killed. The incident occurred on September 12, 1998, in Muntinlupa City. Procedural History: The Regional Trial Court (RTC) of Muntinlupa City found Mallari guilty beyond reasonable doubt of carnapping with homicide and sentenced him to death. The Court of Appeals (CA) affirmed the conviction but modified the penalty to reclusion perpetua, citing Republic Act (RA) No. 9346. The case reached the Supreme Court on appeal. The Petition: Mallari appealed his conviction, assailing the credibility of the sole prosecution witness, Chris Mahilac, and arguing that the evidence was insufficient to prove his guilt beyond reasonable doubt. He also questioned the imposition of the death penalty.
Issue(s)
Whether the guilt of the accused-appellant has been proven beyond reasonable doubt despite the prosecution relying on circumstantial evidence and a sole witness. Whether the penalty imposed by the lower courts was proper.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, finding Reynaldo Mallari guilty beyond reasonable doubt of the special complex crime of carnapping with homicide. The penalty was modified to reclusion perpetua without eligibility for parole. Mallari was also ordered to pay civil indemnity, moral damages, and temperate damages to the heirs of Erico Medel.
Ratio Decidendi
On the issue of guilt beyond reasonable doubt: The Court held that the guilt of Mallari was established by the confluence of circumstantial evidence. Chris Mahilac, a self-confessed member of the "FX gang," testified that Mallari participated in the planning and execution of the carnapping. Mahilac witnessed Mallari flag down the taxi driven by Medel, board it with co-accused, and proceed south. Later, in Cagayan de Oro City, Mallari admitted that Medel was killed for resisting and that his body was dumped in Atimonan, Quezon. The vehicle was subsequently delivered to Pangandag in Lanao del Norte for ₱250,000.00. The discovery of Medel's cadaver in the location indicated by Mallari further corroborated Mahilac's testimony. The Court found Mallari's defense of alibi to be weak and uncorroborated, thus unable to overcome the credible testimonial and circumstantial evidence presented by the prosecution. The elements of carnapping with homicide were all proven: the taking of the vehicle with intent to gain, the killing of the driver in the course of the carnapping, and Mallari's participation therein. On the penalty imposed: The Court reiterated that under Section 14 of RA 6539, as amended by RA 7659, the penalty for carnapping with homicide is reclusion perpetua to death. The trial court imposed the death penalty, considering membership in a syndicated crime group as an aggravating circumstance. However, the Supreme Court ruled that this aggravating circumstance was not alleged in the Information, and thus could not be appreciated against Mallari, as per Rule 110, Section 8 of the Rules of Court, which requires all aggravating circumstances to be alleged. Consequently, applying Article 63(2) of the Revised Penal Code, the lesser penalty of reclusion perpetua was imposed. The Court also noted that under RA 9346, the death penalty can no longer be imposed, and Mallari is not eligible for parole.
Main Doctrine
The special complex crime of carnapping with homicide is established by circumstantial evidence, including the taking of the vehicle with intent to gain, the killing of the driver in the course thereof, and the subsequent disposal of the vehicle and the victim's body. Alibi, being a weak defense, must be corroborated and cannot prevail over credible testimonial evidence.