Criminal Procedure 2E

TOPIC R.A. 7691- An Act Expanding the Jurisdic:on of MTC, MeTC, DATE January 12, 2014
MCTC, amending B.P.129

CASE TITLE People v. A:enza GR NO 188694

DOCTRINE The test to determine whether or not the circumstan:al evidence on record is sufficient to
convict the accused is that the series of circumstances duly proven must be consistent with
each other and that each and every circumstance must be consistent with the accused’s
guilt and inconsistent with his innocence.
FACTS A:enza and Castro are employees of the CA, par:cularly assigned to its Budget Division and
holding the posi:ons of Budget Officer I and U:lity Worker I. A:bula, Records Officer I and
Custodian of the CA Original Decisions in the CA Reporter’s Division, was invited by Castro to
aVend A:enza’s birthday party then introduced him to a certain Dario and asked him to
assist the laVer in searching for the CA decision in the case en:tled “Mateo Fernando v.
Heirs of D. Tuason, Inc.”

A:bula returned to office and thereaYer Dario followed and searched said decision. It was
observed by the former that Dario was comparing its pages to the discolored papers he was
holding, likewise scanned and marked the papers. As they walked side by side towards the
jeepney stop, Dario requested A:bula to insert a Decision dated September 26, 1968 in one
of the volumes of the CA Original Decisions. However, A:bula refused and immediately leY.

A:bula reported the incident, including the bribery of 50,000php, to AVy. Macapagal, the
Assistant Chief of the CA Reporter’s Division, who then instructed him to hide Volumes 260,
265 and 267 in a safe place, but s:ll turned out to be missing at the end.

Nelson de Castro handled to A:bula the missing documents which turned out to have new
documents inserted. Upon review, it was also found that the duplicate original decisions did
not bear such promulga:ons. During the inves:ga:on, it was clear that the signatures of
judges were forged.

A:enza denied all allega:ons.

RTC: Found pe::oners guilty of Robbery and Falsifica:on of Documents

CA: Affirmed RTC's decision

ISSUE/S Whether or not pe::oners’ convic:on for the crimes of Robbery and Falsifica:on of Public
Document should be upheld on account of the circumstan:al evidence in this case proving
their guilt beyond reasonable doubt

RATIO The pe::on is meritorious.

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 The pe::on is meritorious. Criminal Procedure 2E

Circumstan:al evidence consists of proof of collateral facts and circumstances from which the
main fact in issue may be inferred based on reason and common experience. It is sufficient for
convic:on if:
(a) there is more than one circumstance;
(b) the facts from which the inferences are derived are proven; and
(c) the combina:on of all the circumstances is such as to produce a convic:on beyond
reasonable doubt.

To uphold a convic:on based on circumstan:al evidence, it is essen:al that the circumstan:al

evidence presented must cons:tute an unbroken chain which leads one to a fair and
reasonable conclusion poin:ng to the accused, to the exclusion of the others, as the guilty
person.

Applying these principles to the facts that appear on record, the Court finds that no sufficient
circumstan:al evidence was presented in this case to establish the elements of Robbery under
Ar:cle 299 of the RPC and Falsifica:on of Public Documents under Ar:cle 172 in rela:on to
Ar:cle 171 of the same code, or of pe::oners’ supposed conspiracy therefor.

RULING WHEREFORE, the pe::on is GRANTED.

Pe::oners Ricardo L. A:enza and Alfredo A. Castro are hereby ACQUITTED of the crimes of
Robbery and Falsifica:on of Public Document on the ground of reasonable doubt
NOTES A. Par7cipa7on and Evidence Against Castro
The prosecu:on’s evidence on the maVer should be treated as hearsay and, thus,
inadmissible to establish the truth or falsity of the relevant claims. Consequently, there
exists no sufficient circumstan:al evidence to prove Castro’s guilt.

B. The Par7cipa7on of and Evidence Against A7enza

While records show that A:enza was posi:vely iden:fied by A:bula as having aVempted
to bribe him to take out Volume 260 of the CA Original Decisions from the Reporter’s
Division, the fact is that the alleged intercala:on actually occurred in a different document,
that is Volume 266.

It is well–established that mere proof of mo:ve, no maVer how strong, is not sufficient
to support a convic:on, most especially if there is no other reliable evidence from which it
may reasonably be deduced that the accused was the malefactor.

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 Criminal Procedure 2E