Facts:

The case involves Felix L. Arriola (petitioner) and Ma. Theresa Tabuzo (respondent), who were indicted for twenty-one counts of Falsification of Public Document under Article 171 of the Revised Penal Code. The events leading to the indictment began in 2002 when Gregg Business Agency, a local accounting firm, sought to procure community tax certificates (CTCs) for its clients. Rosalinda Pagapong, the agency's Liaison Officer, coordinated with a person known as "Girlie Moore," who was later identified as Tabuzo. On January 17, 2002, Tabuzo visited the agency, received P38,500.00, and promised to deliver the CTCs by January 19, 2002. However, the CTCs were only delivered on January 31, 2002, after repeated follow-ups, and upon verification, they were found to be falsified.

The investigation revealed that the CTCs with serial numbers 15492830 to 15492850 were requisitioned by Arriola, who was then a Local Treasury Operations Officer at the Office of the City Treas...

Facts:

Procedural History and Background

• Felix L. Arriola, an employee of the Manila City Hall and accountable officer of the Office of the City Treasurer, along with Ma. Theresa Tabuzo (also known as “Girlie Moore”), were indicted for twenty-one (21) counts of Falsification of Public Document under Article 171 of the Revised Penal Code.
• The twenty-one separate Informations were consolidated and docketed as Criminal Case Nos. 03-219432 to 03-219452 before the Regional Trial Court (RTC) of Manila.
• The case stemmed from a transaction involving Gregg Business Agency, a local accounting firm, which required community tax certificates (CTCs) for its clients in 2002.

Factual Circumstances

• The accounting firm needed CTCs for twenty-one clients and engaged Rosalinda Pagapong, its Liaison Officer, to coordinate with “Girlie Moore” for their procurement.
• “Girlie Moore” visited the agency on January 17, 2002, after receiving a total fee of ₱38,500.00, and promised delivery of the CTCs by January 19, 2002; however, delivery only occurred on January 31, 2002 after several follow-ups.
• The delivery took place at the Inner Court of the Manila City Hall, where Pagapong received the CTCs and proceeded to obtain an Order of Payment from the City Treasurer’s Office.
• Shortly afterward, the falsified nature of the CTCs came to light when, upon verification by Liberty M. Toledo, then City Treasurer, the CTCs (bearing Serial Nos. 15492830 to 15492850) were found inconsistent with official records.
• Further investigations revealed:
• The CTCs in question were originally stamped as “UNEMPLOYED” and meant for unemployed residents at a standard fee of ₱5.00 each.
• The same control numbers had been requisitioned by Arriola through official channels, raising suspicions about their subsequent duplication or alteration.
• Subsequent inquiries identified “Girlie Moore” not as an independent contractor but as Ma. Theresa Tabuzo, an employee of the Manila City government, implicating a possible conspiracy.

Pre-Trial and Trial Developments

• At arraignment, Arriola pleaded not guilty and voluntarily surrendered with bail, while Tabuzo also pleaded not guilty but later absconded, leading to a trial in her absence.
• During the pre-trial, certain facts were stipulated, including Arriola’s employment and official responsibilities, particularly in the requisition and handling of CTCs.
• The RTC, in its consolidated judgment rendered on April 12, 2012, found that despite the absence of direct evidence tying Arriola to the falsification, the circumstantial evidence established “with moral certainty” his complicity, and by extension, that of Tabuzo as his accomplice.
• The Court of Appeals (CA) later affirmed the RTC’s findings in its September 15, 2014 Decision and denied a subsequent motion for reconsideration in its March 6, 2015 Resolution.

Evidentiary Highlights

• Documentary evidence included:
• The Requisition Slip and Accountable Forms Control Card evidencing the issuance of 1,000 pieces of Class A CTCs on January 18, 2002 with specific control numbers.
• Records showing that on January 21, 2002, Arriola remitted collections for the issued CTCs.
• Testimony indicating that the CTCs delivered later by Tabuzo to Pagapong were different in nature (classified as Class B, with higher fees) and inconsistent with the originals.
• Testimony of prosecution witness Liberty M. Toledo, which inferred that as the accountable officer who processed the CTCs, Arriola was in a unique position to have perpetrated the said falsification.
• The inherent inconsistencies in the timeline and handling of the CTCs raised doubts about whether only Arriola was involved, or whether others (possibly his subordinates) could have been the actual perpetrators.

Issue:

Sufficiency of the Prosecution’s Evidence

• Whether the circumstantial evidence presented by the prosecution established, beyond reasonable doubt, the fact that Arriola falsified the public documents.
• Whether the evidence, taken in totality, created a moral certainty linking Arriola to the alterations in the CTCs bearing specific control numbers.

Applicability of Legal Authorities

• Whether the legal principles and authorities cited by the lower courts to support the conviction are applicable and sufficient in establishing guilt.
• Whether reliance on circumstantial evidence, absent direct proof, meets the rigorous demands of proving criminal liability in this case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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