People vs. Prado

G.R. No. 95260 (March 8, 1996)

Wilfredo Prado y Cabrera was convicted of carnapping with homicide; appeal affirmed.

Facts:

On May 12, 1987, Samuel Moulic, a tricycle driver, was last seen operating his tricycle, a Honda motorcycle with plate number AC-8801, in the municipality of Mangaldan, Pangasinan. He was reported missing by his family when he failed to return home that night. The following day, his body was discovered bearing multiple stab wounds along the boundary of Bigabiga and Rabon, San Fabian, Pangasinan.

The accused, Wilfredo Prado y Cabrera, along with two other individuals, was charged with carnapping and homicide. Evidence presented by the prosecution indicated that on the same day Samuel was last seen, Prado was observed pushing the tricycle and later hired a witness, Elpidio Rivera, to tow it. Subsequently, Prado attempted to sell the motorcycle to Edgardo Gomez, who became suspicious when Prado could not produce the registration papers. Despite this, Prado executed a sale agreement with Gomez, receiving partial payment.

On May 15, 1987, Prado sold the sidecar of the tricycle to another individual, Benito Buenavista. The police later found the motorcycle abandoned at a gasoline station. The prosecution's case relied heavily on circumstantial evidence, including the timeline of events and Prado's actions following the incident.

Legal Issues:

  1. Whether the trial court erred in convicting the accused based on circumstantial evidence.
  2. Whether the accused was correctly convicted as a principal in the crime rather than as an accessory after the fact.
  3. Whether the trial court erred in disregarding the testimony of the defense witness, Leticia Araos.

Arguments:

Prosecution:

  • The prosecution argued that the circumstantial evidence presented formed a coherent narrative that established Prado's guilt beyond a reasonable doubt. They highlighted the timeline of events, including Samuel's last known whereabouts, the discovery of his body, and Prado's subsequent actions in selling the motorcycle.
  • The prosecution maintained that the evidence was sufficient to establish an unbroken chain of events leading to Prado's conviction for carnapping with homicide.

Defense:

  • Prado contended that he was merely acting as an agent for his co-accused, Peter Aquino and George, in selling the motorcycle and claimed he received a small fee for facilitating the sale.
  • The defense also argued that the circumstantial evidence was insufficient for a conviction and that the trial court failed to give proper weight to the testimony of Leticia Araos, who claimed that Prado was not involved in the crime.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding that the circumstantial evidence was indeed sufficient to convict Prado. The court emphasized that circumstantial evidence does not hold a lesser status than direct evidence and can be sufficient for conviction if it meets certain criteria. The court identified several key circumstances that pointed to Prado's guilt, including:

  1. Samuel Moulic's last known location and the subsequent discovery of his body.
  2. Prado's possession and sale of the motorcycle shortly after the crime.
  3. The testimony of witnesses that linked Prado to the crime scene and the stolen vehicle.

The court also addressed the defense's claims regarding the credibility of witnesses, stating that the trial court was in a better position to assess the credibility of the testimonies presented. The court found no improper motive on the part of the prosecution's key witness, Edgardo Gomez, and thus upheld the trial court's assessment of the evidence.

In terms of penalties, the court noted that under Republic Act No. 6539, the crime of carnapping with homicide warranted a penalty of reclusion perpetua, given that the death occurred in the course of the carnapping. The court also modified the damages awarded to the heirs of the victim, increasing the civil indemnity to P50,000.00.

Significant Legal Principles Established:

  • Circumstantial evidence can be sufficient for conviction if it meets the criteria outlined in the Revised Rules of Court.
  • The credibility of witnesses is primarily determined by the trial court, which has the advantage of observing their demeanor during testimony.
  • The presumption of guilt can arise when an accused is found in possession of stolen property shortly after a crime, particularly when the owner has been harmed.