People V. Macaranas

PEOPLE OF THE PHILIPPINES v.
JEFFREY MACARANAS Y
FERNANDEZ, G.R. No. 226846, June 21, 2017
Facts:
On Febriary 18, 2007, Frank Langaman and his girlfriend Kathlyn Irish Mae
Cervantes were at Meyland Village, Meycauayan, Bulacan. They were aboard
a green Honda Wave 125 with Plate No. NQ 8724, registered under Jacqueline
Langaman. Suddenly, two men wearing jackets and bonnets approached them.
A third man who earlier was standing at a post followed. One of the three held
Frank by the neck and shot Frank causing him to fall down. The same man
pointed his gun at Kathlyn and demanded her cellphone. Kathlyn gave her
cellphone and the same man hit her on the back. Kathlyn pretended to be
unconscious and saw that the men searched the body of Frank for any
valuables. While the incident was taking place, the second man took Frank's
motorcycle, while the third man identified as Jeffrey Macaranas, just stood
guard and acted as the look-out. The three men left together riding Frank's
motorcycle. Kathlyn seek help and Frank was taken to the hospital.
Frank sustained a gunshot injury traversing the neck area which necessitated
surgery. Eventually, Frank died on March 30, 2007. The cause of death was
"cardio pulmonary arrest secondary to the spinal cord injury with retained
metallic foreign body secondary conjunction injury status post the surgery
done which is laminectomy infusion with rods and screws”.
An Information was then filed against Jeffrey Macaranas, Richard Lalata and a
certain John Doe charging them of violation of R.A. No. 6539.
Defense of the Accused:
Macaranas denied the charges and claimed that on February 18, 2007, he fetched his
cousin Richard Lalata and proceeded to his father’s house at Brgy. Lawa. They then
left early in the morning of the following day and just slept the whole day at their
house in Brgy. Daungan. Sometime in June 2007, barangay officials arrested hi.
Macaranas claimed that he was beaten and mauled in order to admit that he killed
Frank, and under coercion, he pointed to his cousin Richard Lalata as the perpetrator.
Decision of the RTC:
The RTC found Macaranas guilty beyond reasonable doubt of the offense
charged.
Decision of the CA
On appeal, the CA affirmed the decision of the RTC with modification.
Issue:
1) Whether the testimony of the lone witness is enough to convict the accused;
2) Whether the accused was guilty of Carnapping
1. The SC held that there was indeed a positive and unequivocal identification of the
accused. It has long been settled that where the witnesses of the prosecution were not
actuated by ill motive, it is presumed that they were not so actuated and their
testimony is entitled to full faith and credit. Here, no imputation of improper motive
on the part of Kathlyn was ever made by Macaranas, as the he even testified he was
without knowledge of any grudge Kathlyn might have against him. Further,
relationship per se of Kathlyn with the victim does not necessarily mean that her
testimony is biased and/or fabricated.
Conspiracy was also proven in this case. In this case, conspiracy was evident from the
coordinated movements of the three accused. Macaranas was seen standing by the
post looking at Kathlyn and the victim aboard the motorcycle. When his co-accused
approached the Kathlyn, Macarans followed and was standing guard nearby, while his
companions committed their criminal acts. After the victim fell down, and apparently
thinking Kathlyn to be unconscious, the trio left together taking with them the victim's
motorcycle. Clearly, Macaranas and his company all acted in confabulation in
furtherance of their common design and purpose, i.e., to carnal the motorcycle.
2. Yes. R.A. No. 6539, or the Anti-Carnapping Act of 1972, as amended, defines
carnapping as the taking, with intent to gain, of a motor vehicle belonging to another
without the latter's consent, or by means of violence against or intimidation against
persons, or by using force upon things.
The elements of carnapping as defined and penalized under R.A. No. 6539, as
amended are the following:
1) That there is an actual taking of the vehicle;
2) That the vehicle belongs to a person other than the offender himself;
3) That the taking is without the consent of the owner thereof; or that the taking was
committed by means of violence against or intimidation of persons, or by using force
upon things; and
4) That the offender intends to gain from the taking of the vehicle.
In this case, all the elements are present as the pieces of evidence presented by the
prosecution show that there were two men both wearing jackets and bonnets, together
with Macaranas who approached the victim and the witness Kathlyn and employed
force and intimidation upon them and forcibly took the victim's motorcycle and then
shot the victim on the neck causing his death.

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PEOPLE OF THE PHILIPPINES v.

Defense of the Accused:

Decision of the RTC:

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