**People of the Philippines v. Artemio Garcia y Cruz, Jr., and Regalado Bernabe y Orbe: A Case of Carnapping with Homicide under Republic Act No. 6539**
### Facts:
On December 21, 1996, Artemio Garcia, Jr. and Regalado Bernabe were charged with Carnapping with Homicide for forcibly taking and later killing Wilfredo Elis, the driver of a leased Toyota Tamaraw FX, owned by Fernando Ignacio. The incident took place in San Rafael, Bulacan, Philippines. Both accused pleaded not guilty and underwent trial.
The series of events began on December 17, 1996, when Garcia and Bernabe sought to borrow a Mitsubishi L300 van from Joselito Cortez, a taxicab operator, for a trip to the Bicol region. Upon refusal, Cortez arranged for them to lease Ignacio’s brand new Toyota Tamaraw FX. The agreement was at P4,000.00 a day, including a P500.00 driver’s fee, payable upon return. However, after leaving for Bicol on December 18, 1996, and cease of communication from the accused, Cortez and Nancy Elis (Wilfredo’s wife) became worried.
Subsequently, on December 23, 1996, SPO2 Emmanuel Lapurga reported two individuals attempting to sell the aforementioned vehicle in Tarlac for P50,000.00, leading to the apprehension of Garcia and Bernabe. Their attempt to involve Elis in their plan resulted in his murder when he refused, which they confessed to Cortez.
Despite claims of innocence and inconsistencies in their accounts, forensic and circumstantial evidence linking them to the crime was overwhelming, leading to their conviction by the Regional Trial Court of Malolos, Bulacan.
### Issues:
1. Whether all elements of carnapping, as defined in Republic Act No. 6539, were present and duly proven.
2. Whether the trial court erred in holding Bernabe as part of the conspiracy to commit carnapping.
3. Whether the trial court erred in convicting Bernabe based on his alleged admission of the crime to private individuals.
### Court’s Decision:
1. **On the Elements of Carnapping**: The Supreme Court affirmed that all elements of carnapping were present—unlawful taking of the vehicle with intent to gain, without the owner’s consent, and through violence.
2. **On Conspiracy**: The Court held that conspiracy was evident through the coordinated actions of Garcia and Bernabe in taking the vehicle and attempting to sell it, fulfilling the requisite intentional agreement to commit carnapping and homicide.
3. **On Admission to Private Individuals**: The Court determined that the confessions to Cortez were admissible, given freely and voluntarily, thereby constituting direct linkage to the crime.
The Supreme Court affirmed the trial court’s decision but modified the moral damages awarded and deleted the award for loss of earnings due to lack of substantiation.
### Doctrine:
– The definition and elements of carnapping under Republic Act No. 6539: Unlawful taking, with intent to gain, without the owner’s consent, through violence, intimidation, or force.
– Confessions made voluntarily to private individuals are admissible in court, as protected under the delineation of rights against self-incrimination which does not apply to spontaneous admissions.
### Class Notes:
– **Elements of Carnapping with Homicide**: (1) Actual taking of the vehicle; (2) Intent to gain; (3) Vehicle belonging to another; (4) Taking without consent or through violence/intimidation; (5) Homicide committed in the course or on occasion of Carnapping.
– **Constitutional Rights in Custodial Investigation**: Spontaneous statements made freely and voluntarily to a private individual are admissible in court.
– **Conspiracy**: Defined by a joint purpose, concerted action, and concurrence of sentiments among individuals; in carnapping, it implicates direct participation and shared responsibility in the act.
– **Admissibility of Confessions**: Section 12, Article III of the Philippine Constitution disallows the compulsion of self-incriminating evidence, i.e., coerced confessions but does not apply to voluntary admissions to non-authorities.
### Historical Background:
The decision in this case encapsulates the Philippines’ legal stance on carnapping with homicidal actions, showcasing judicial procedures and evidential standards required to establish guilt. It reasserts the importance of protecting property rights and human life, underlining the severe penalties for such crimes to deter future occurrences, aligned with Republic Act No. 6539’s objective to penalize and prevent carnapping.
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