Atienza vs People, G.R. No.

188694, February 12, 2014

FACTS:

This case involves crimes of Robbery and Falsification of Public Document against
 Atienza and Castro.
Castro. Atienza
Atienza and
and Castro
Castro !etitioners"
!etitioners" are em!loyees
em!loyees of the CA#
!articularly assigned to its $udget Division and holding the !ositions of $udget %fficer &
and 'tility (or)er &.

 Abitula# Custodian
Custodian of CA decisions *as invited
invited by Castro
Castro to attend
attend Atienza+s
Atienza+s !arty
!arty
*here the latter introduced Atibula to a certain Dario and as)ed him to assist in
searching for the CA decision. Thereafter# Atibula and Dario returned to the office and
searched for the decision. Dario re,uested Atibula to insert a decision in one of the
volumes of CA %riginal Decisions *here the latter refused and immediately left. Atienza
offered Atibula -# in e/change for records. Atibula re!orted the incident. 0e further
discovered that some of the volumes *ere missing *hich he also re!orted.

1elson de Casto# Cler) &2 detailed at the CA Re!orter+s Division handed to Atibula a
bag containing a gift3*ra!!ed !ac)age *hich turned out to be the missing records. 0e
claimed that it *as Castro *ho as)ed him to deliver the said !ac)age to Atibula.

The contents of the returned records *ere revie*ed by Atibula and it *as found that
there *ere ne* documents inserted therein. '!on Atibula+s com!arison# it *as found
that the du!licate original decisions did not bear such !romulgations. %n investigation# it
*as found that the signatures of the 4ustices *ere forged.

 Atienza denied the

the allegations.
allegations.

RTC found that there is cons!iracy. CA affirmed RTCs decision.

&SS'5: Are the circumstantial evidence sufficient to *arrant a conviction

R'6&
R'6&17
17:: 1o.
1o. Circ
Circum
umst
stan
anti
tial
al evid
eviden
encece cons
consis
ists
ts of !roo
!rooff of coll
collat
ater
eral
al fact
facts
s and
and
circumstances from *hich the main fact in issue may be inferred based on reason and
commo
common n e/!e
e/!erie
rience
nce.. &t is suff
suffici
icien
entt for
for conv
convict
iction
ion if: a"
a" there
there is more
more than
than one
one
circumstance8 b" the facts from *hich the inferences are derived are !roven8 and c"
the combination of all the circumstances is such as to !roduce a conviction beyond
reasona
reasonable
ble doubt.
doubt. To u!hold a convicti
conviction
on based
based on circumst
circumstant
antial
ial evidenc
evidence#
e# it is
essential
essential that the circumstantial
circumstantial evidence
evidence !resented must constitute
constitute an unbro)en
unbro)en chain
*hich leads one to a fair and reasonable conclusion !ointing to the accused# to the
e/clusion of the others# as the guilty !erson. Stated differently# the test to determine
*hether or not the circumstantial evidence on record is sufficient to convict the accused
is that the series of circumstances duly !roven must be consistent *ith each other and
that each and every circumstance must be consistent *ith the accused+s guilt and
inconsistent *ith his innocence.

The burden lies on the !rosecution to overcome such !resum!tion of innocence# failing
*hich# the !resum!tion of innocence !revails and the accused should be ac,uitted.
This# des!ite the fact that his innocence may be doubted# for a criminal conviction rests
on the strength of the evidence of the !rosecution and not on the *ea)ness or even
absence of defense. &f the incul!atory facts and circumstances are ca!able of t*o or 
more e/!lanations# one of *hich is consistent *ith the innocence of the accused and
the other consistent *ith his guilt# then the evidence does not fulfill the test of moral
certainty and is not sufficient to su!!ort a conviction# as in this case. Courts should be
guided by the !rinci!le that it *ould be better to set free ten men *ho might be !robably
guilty of the crime charged than to convict one innocent man for a crime he did not
commit.

 Accordingly# there being no circumstantial evidence sufficient to su!!ort a conviction#

the Court hereby ac,uits !etitioners# *ithout !re4udice# ho*ever# to any subse,uent
finding on their administrative liability in connection *ith the incidents in this case.