The Supreme Court granted the appeal of Kristian Singh y Montemayor and acquitted him of carnapping under Section 3 of Republic Act No. 10883 in Criminal Case No. L-13052 on the ground of reasonable doubt. In the same decision, the Court found accused CICL1 guilty of carnapping, and dismissed the case against CICL2 and CICL3, also on the ground of reasonable doubt.
The Case
Through an Information dated January 22, 2020, docketed before the Regional Trial Court (RTC) as Criminal Case No. L-13052, Singh and his co-accused CICL1, CICL2, and CICL3 were indicted for carnapping under Republic Act No. 10883. The Information alleged that sometime in the morning of January 20, 2020 in Pangasinan, the accused, including three minors said to have acted with discernment, in conspiracy with each other, willfully and unlawfully took with intent to gain a Rusi 150 motorcycle belonging to Jennifer L. Villacorta without her consent.
Arraigned on January 29, 2020, Singh pled not guilty. CICL1 (aged 17), CICL2 (aged 16), and CICL3 (aged 15) entered pleas of guilty. The three children in conflict with the law (CICL) were sentenced to imprisonment of 20 years and one day, as minimum, to 21 years, as maximum, and were granted automatic suspension of sentence under Section 38 of Republic Act No. 9344, being committed to the custody of the Center Head of the Regional Rehabilitation Center for Youth in Urayong, Bauang, La Union.
According to the prosecution, on January 20, 2020, at around 7:05 a.m., Villacorta was roused from her sleep by her mother, Zorayda B. Liquiran, who asked where her motorcycle was. Villacorta said she last saw it at 3 a.m. near carnival rides where her nephew parked it. At around 11:45 a.m., Villacorta and Liquiran reported the missing motorcycle to the police. A confidential informant tipped police that a motorbike was being dismantled in a barangay about 500 to 700 meters away. Police Staff Sergeant Scepter E. Aguinaldo and another officer, with Villacorta and Liquiran, found a motorcycle being disassembled by four individuals — later identified as Singh and the three CICLs — in front of a house. After confirming that the engine and chassis numbers matched Villacorta's, the officers arrested the four.
Singh's defense was that he only helped fix the motorcycle, which CICL1 claimed to own. CICL1 himself professed that he stole Villacorta's motorcycle by himself and only asked Singh, CICL2, and CICL3 for help in fixing it, telling them he owned the vehicle.
The Issue
The Court examined whether the prosecution proved beyond reasonable doubt the guilt of Singh and the co-accused for carnapping, including whether the CICL acted with discernment as required under the law governing children in conflict with the law.
The Ruling
The Court held that CICL1 carried out the carnapping with discernment, but the same could not be said of CICL2 and CICL3. The prosecution neglected to specifically prove that CICL2 and CICL3 acted with discernment, creating a vacuum in the evidence and reasonable doubt as to their culpability. As for Singh, his exoneration was likewise warranted on the ground of reasonable doubt.
The dispositive portion states: "FOR THESE REASONS, the Appeal is GRANTED. The March 7, 2023 Decision of the Court of Appeals in CA-G.R. CR-HC No. 15836 is REVERSED and SET ASIDE." Singh was ACQUITTED and ORDERED IMMEDIATELY RELEASED unless held for another lawful cause. CICL1 was found GUILTY and SENTENCED to 20 years and one day to 21 years of imprisonment. The case was DISMISSED as against CICL2 and CICL3, who were ordered immediately released from the Regional Rehabilitation Center for Youth. The case was REMANDED for proper disposition in accordance with Section 51 of Republic Act No. 9344.
By the Numbers
- G.R. No. 270284
- Information dated January 22, 2020
- Criminal Case No. L-13052
- Incident: January 20, 2020, around 7:05 a.m.
- Report to police: around 11:45 a.m.
- CICL ages: 17, 16, and 15
- Sentence for CICL1: 20 years and one day to 21 years
- CA Decision reversed: March 7, 2023 (CA-G.R. CR-HC No. 15836)
- Carnapping penalty under Section 3, R.A. No. 10883: not less than 20 years and one day, but not more than 30 years, when committed without violence or force upon things
The Court's Reasoning
The Court explained that under the prevailing framework for cases involving children in conflict with the law under Republic Act No. 9344, as amended by Republic Act No. 10630, together with the 2019 Supreme Court Revised Rule on Children in Conflict with the Law, discernment must be separately established beyond reasonable doubt. Because the prosecution failed to prove that CICL2 and CICL3 acted with discernment, they had to be absolved. Singh, CICL2, and CICL3's exoneration was warranted on reasonable doubt, and the Court found no compelling reason to tackle other issues such as the validity of Singh's warrantless arrest or Villacorta's legal personality.
On the penalty for CICL1, the Court noted that carnapping without violence or force is punishable by imprisonment of not less than 20 years and one day but not more than 30 years, and that the sentence imposed fell within the statutory range. CICL1 is no longer entitled to suspension of sentence under Section 38 of Republic Act No. 9344, since suspension may only continue until the offender reaches 21 years of age under Section 40. However, CICL1 may enjoy the benefits of Section 51 of Republic Act No. 9344, allowing confinement in an agricultural camp or other training facility in lieu of a regular penal institution.
Source: Supreme Court Decision in G.R. No. 270284.
This report summarizes a public Supreme Court decision and is not legal advice.