Case Digest (G.R. No. 62386) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ricardo L. Atienza and Alfredo A. Castro v. People of the Philippines (G.R. No. 188694, February 12, 2014), petitioners Atienza (Budget Officer I) and Castro (Utility Worker I) of the Court of Appeals’ Budget Division were accused of robbing and falsifying a volume of original decisions. On March 20, 1995, Records Officer Juanito Atibula discovered that Volume 266 of the CA Original Decisions was missing after having been compared with discolored loose pages at the CA Reporteras Division. Subsequent invitations to Atibula by petitioners to retrieve other volumes with offers of money, and Atibula’s refusal, preceded the loss. On May 9, 1995 Atibula reported the absence of Volume 266, and on May 18 a clerk delivered the volume wrapped as a gift, purportedly at Castro’s instruction. Laboratory examinations by the NBI confirmed tampering and forged judicial signatures, revealing two inserted documents amending a 1968 decision. A complaint charged petitioners with Robbery under Ar... Case Digest (G.R. No. 62386) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners Ricardo L. Atienza (Budget Officer I) and Alfredo A. Castro (Utility Worker I) were employees of the Court of Appeals (CA) Budget Division.
- Juanito Atibula, Records Officer I and custodian of CA Original Decisions in the CA Reporteras Division, was responsible for safeguarding volumes of published CA decisions.
- Events Leading to the Disappearance and Return of Volume 266
- March 20, 1995 – Castro invited Atibula to Atienza’s birthday party, where Atienza asked Atibula to retrieve the CA decision in Mateo Fernando v. Heirs of D. Tuason, Inc. (CA-G.R. No. 36808-R) from Volume 260. A companion, “Dario,” examined Vols. 260, 265, and 267, marking discolored pages.
- March 24, 1995 – Outside office hours, Dario asked Atibula to insert a decision dated September 26, 1968 into a volume. Atibula refused.
- April 21, 1995 – Atienza offered Atibula ₱50,000 for Volume 260; Atibula refused and reported the approach to Atty. Arnel Macapagal, who secured Vols. 260, 265, and 267.
- May 9, 1995 – Atibula discovered Volume 266 (Jan. 28–Feb. 12, 1969) missing and reported to Atty. Macapagal. Two days later, he encountered Atienza angrily shouting at him.
- May 18, 1995 – Nelson de Castro delivered a gift-wrapped package to Atibula containing the missing Volume 266, allegedly at Castro’s instruction.
- NBI Investigation – Laboratory analysis (Questioned Documents Report No. 937-1295) established that Volume 266 had been tampered with and that purported signatures of CA Justices on two inserted documents (a February 11, 1969 Resolution and an April 16, 1970 Decision) were forgeries. An ocular inspection revealed entry through a corroded air-conditioning opening.
- Criminal Proceedings
- Ombudsman Findings – Probable cause to charge petitioners and Dario with Robbery (RPC Art. 299(a)(1)) and Falsification of Public Document (RPC Arts. 171(6) & 172(1)); administrative charges under RAs 3019 and 6713 were dismissed.
- RTC Trial and Decision – On June 8, 2006, the RTC convicted Atienza and Castro of Robbery and Falsification of Public Document, sentencing them to indeterminate imprisonment for robbery and prision correccional plus fine for falsification.
- CA Appeal – On November 28, 2008, the Court of Appeals affirmed the RTC decision, finding sufficient circumstantial evidence and inferred conspiracy. A motion for reconsideration was denied on July 7, 2009.
Issues:
- Whether the conviction for Robbery under RPC Art. 299(a)(1) and Falsification of Public Document under RPC Arts. 171(6) & 172(1) is sustainable on the basis of circumstantial evidence.
- Whether the RTC had jurisdiction over the falsification case punishable with prision correccional medium and maximum periods.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)