CA upholds carnapping charge vs Ateneo shooting suspect Yumol



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The Court of Appeals has upheld the carnapping charge against Chao-Tiao II Yumol, ruling that the indictment sufficiently alleged that he took a Honda Civic at gunpoint while fleeing after the 2022 shooting at Ateneo de Manila University.
In a decision promulgated 30 July, the CA’s 13th Division dismissed Yumol’s petition challenging the Quezon City Regional Trial Court’s refusal to quash the carnapping case, finding no grave abuse of discretion.
Yumol argued that the information charging him with carnapping was defective because it merely stated legal conclusions and failed to detail how he allegedly took the vehicle or how violence or intimidation was used.
The CA disagreed, ruling that the information sufficiently alleged the elements of carnapping under Republic Act 10883, or the New Anti-Carnapping Act of 2016.
The information alleged that on 24 July 2022, Yumol took a Honda Civic with plate number ULF-226, driven by Johnny Palma and registered to Edna Torres, without the owner’s consent and “at gunpoint.”
The court said the allegations sufficiently identified the vehicle, its registered owner and driver, and the manner in which it was allegedly taken.
It also rejected Yumol’s argument that prosecutors should have specified the type of firearm used, saying an information need only allege the ultimate facts constituting the offense and not every detail that may later be established during trial.
The CA said the phrase “at gunpoint” adequately described the alleged use of violence or intimidation against Palma.
The court likewise rejected Yumol’s argument that prosecutors failed to establish intent to gain, saying it is an internal act that may be inferred from the unlawful taking of another person’s property and does not require a specifically identified benefit.
Yumol also argued that the carnapping charge should be absorbed by the murder charges arising from the Ateneo shooting because the vehicle was allegedly taken to facilitate his escape.
The CA rejected the argument, saying the use of a motor vehicle qualifies a killing as murder only when the vehicle itself is used as a means of committing the killing.
Since the Honda Civic was allegedly taken only after the shooting to facilitate Yumol’s escape, it could not have been the means by which the killings were committed, the court said.
The case stemmed from the 24 July 2022 shooting at the Ateneo campus in Quezon City.
Prosecutors alleged that Yumol took Palma’s Honda Civic at gunpoint while fleeing the scene and later abandoned it at a Petron gas station along Aurora Boulevard after allegedly striking the footrest of a motorcycle driven by Raffy Degones.
Yumol was later arrested after boarding a modern jeepney.
Separate criminal cases for three counts of murder, frustrated murder and carnapping were subsequently filed against him.
The Quezon City RTC earlier denied Yumol’s motion to quash the carnapping information, ruling that the allegations sufficiently informed him of the nature and cause of the charge. The CA affirmed the ruling.