People Vs Mejia Case Digest

People Vs Mejia
Facts:
In the evening of 10 March 1994, along the expressway at Barangay Ventinilla,

Sta. Barbara,Pangasinan, several persons on board a passenger jeepney driven by
Teofilo Landingin attacked the latter and a passenger, Virgilio Catugas, thereby
inflicting upon them multiple stab wounds. Landingin was pulled out from his
seat and dumped on the shoulder of the road. One of the attackers took the wheel
of the jeepney and drove away. Catugas was thrown out to the middle of the road
when the jeepney started to move away. Landingin died as a consequence of the
injuries he sustained. Catugas survived.
Despite service on them of subpoenas requiring submission of counter affidavits,

accused Mejia, Benito, Paraan, and Fabito did not submit their counter-affidavits.,
Judge Lilia C. Espanol issued an order declaring the accused "to have waived their
right to be heard in preliminary investigation"; finding a prima facie case against
the accused; recommending that they be charged with and prosecuted for the
crimes of murder, frustrated murder, and violation of R.A. No. 6539, as amended;
and ordering that the records of the cases be forwarded to the Office of the
Provincial Prosecutor for appropriate action.
Held to account for the above acts were Gregorio Mejia, Edwin Benito, Pedro
Paraan, Joseph Fabito, Romulo Calimquim, one alias Dennis, Alex Mamaril, one
alias Mondragon, and another unidentified person. Mejia and Benito were taken
into police custody a few hours after the incident; Paraan, the following day; and
Fabito, five days after. Calimquim was found dead three days after the incident
in question, while the others have remained at large. Three separate criminal
complaints for murder, frustrated murder, and violation of R.A. No. 6539 (Anti
Carnapping Act of 1992, as amended) were filed against them.
The case for Murder & Frustrated Murder where assigned to Branch 44 of the RTC
of Dagupan City presided by Judge Crispin C. Laron.
The third case R.A. No. 6539 (Anti Carnapping Act of 1992, as amended was
assigned to Branch 43 of the said court presided by Judge Silverio Q. Castillo
On LARON court convicted accused Mejia, Benito, Paraan, and Fabito of the crime
of murder and of frustrated murder, with treachery as the qualifying
circumstance and nighttime and band as aggravating circumstances.
Accordingly, it sentenced the first three accused to suffer the penalty of death
for the crime of murder; and ten years and one day of prision mayor to seventeen
years, four months, and one day of reclusion temporal for the crime of frustrated
murder. It credited Paraan with the privileged mitigating circumstance of
minority, he being only seventeen years old at the time of the commission of the
crimes charged; and sentenced him to reclusion perpetua for murder, and six
years of prision correccional to ten years and one day of prision mayor for
frustrated murder. The Court also ordered the four accused to pay the heirs of
Teofilo Landingin the amounts of P50,000 as death indemnity; P16,000 for the
cost of the tomb; and P12,000 for funeral expenses; and to pay Catugas the
amount of P44,687.25 for hospital expenses, plus costs.
On the Castillo Court the court then convicted accused Gregorio Mejia, Edwin
Benito, Pedro Paraan, and Joseph Fabito guilty of the violation of the Anti-
Carnapping Act of 1972, as amended. It sentenced the first three accused to
death; and Paraan, to reclusion perpetua on account of the privileged mitigating
circumstance of minority.
Although review in cases where the death penalty is imposed by the trial court
is automatic pursuant to Section 22 of R.A. No. 7659. The convicted accused
filed with this Court their notices of appeal from the decision of the LARON
court and of the CASTILLO court on 18 November 1994 and 22 February 1995,
respectively.
The appellants filed a motion for the consolidation of these cases, which we
granted on 27 February 1996.
Issue:
WON they committed RA 6759
Held:
The accused admitted to having flagged down and boarded Landingin's jeepney
that fateful evening of 10 March 1994, but denied having committed the crimes.
They claimed that it was Romulo Calimquim and his companions who killed
Landingin, stabbed Catugas, and drove away the jeepney.
The latter makes clear the intention of the law to make the offense a special
complex crime, by way of analogy vis-a-vis paragraphs 1 to 4 of Article 294 of
the Revised Penal Code on robbery with violence against or intimidation of
persons. As such, the killing (or the rape) merely qualifies the crime of
carnapping which for lack of specific nomenclature may be known as qualified
carnapping or carnapping in an aggravated form . In short, considering the
phraseology of the amended Section 14, the carnapping and the killing (or the
rape) may be considered as a single or indivisible crime or a special complex
crime which, however, is not covered by Article 48 of the Revised Penal Code.
It follows then that the killing of the driver, Teofilo Landingin — whether it be
homicide or murder — cannot be treated as a separate offense, but should only
be considered to qualify the crime of carnapping.
If attempted or frustrated murder or homicide is committed "in the course of the

commission of the carnapping or on the occasion thereof," then it must be
deemed to fall under the clause (of Section 14) "when the carnapping is
committed by means of violence against or intimidation of any person."
The evidence adduced by the prosecution has established beyond reasonable

doubt the carnapping of Teofilo Landingin's passenger jeepney, which is a motor
vehicle under the definition in Section 2 of R.A. No. 6539. The passenger jeepney
was taken, with intent of gain, from Landingin by means of violence against him
which caused his death and against a passenger, Virgilio Catugas, who suffered
physical injuries.
Unfortunately, the CASTILLO court relied heavily on the entries in the police
blotters of the police stations of Sual and Sta. Barbara. The silence of the entries
on what the appellants had declared in court is not conclusive evidence that they
did not report the incident to the police authorities. They had no participation in
the preparation of the entries. Entries in the police blotters should not be given
undue significance or probative value, for they are normally incomplete and
inaccurate sometimes from either partial suggestion of for want of suggestion or
inquiries.
As to the alleged participation of the appellants in the commission of the crimes,

the prosecution had to rely solely on the testimony of Virgilio Catugas. The
totality of his testimony in the cases before the LARON court leaves much to be
desired. The prosecutor who conducted the direct examination was unable to
propound sensible questions to elicit clear answers bound to reconstruct
faithfully the events surrounding the commission of the alleged crimes.
Accused-appellants Gregorio Mejia, Edwin Benito, Pedro Paraan, and Joseph

Fabito are ACQUITTED on the ground that their guilt therefor has not been
proved beyond reasonable doubt or with moral certainty. Their immediate
release from detention is hereby ordered, unless other lawful and valid grounds
for their further detention exist.

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People Vs Mejia

In the evening of 10 March 1994, along the expressway at Barangay Ventinilla,

Despite service on them of subpoenas requiring submission of counter affidavits,

WON they committed RA 6759

If attempted or frustrated murder or homicide is committed "in the course of the

The evidence adduced by the prosecution has established beyond reasonable

As to the alleged participation of the appellants in the commission of the crimes,

Accused-appellants Gregorio Mejia, Edwin Benito, Pedro Paraan, and Joseph

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