Facts:

The case involves petitioners Ricardo L. Atienza and Alfredo A. Castro, who were employees of the Court of Appeals (CA) in the Philippines, specifically assigned to the Budget Division. The events leading to the case began on March 20, 1995, when Juanito Atibula, a Records Officer I at the CA, was invited by Castro to attend Atienza's birthday party in Ermita, Manila. During the party, Atienza introduced Atibula to a man named Dario, who was searching for a CA decision in the case Mateo Fernando v. Heirs of D. Tuason, Inc. Atibula later returned to the office, followed by Dario, who was seen comparing pages of the CA Original Decisions with discolored papers he held.

On March 24, 1995, Atibula encountered Dario again, who requested him to insert a decision into one of the volumes of the CA Original Decisions, which Atibula refused. On April 21, 1995, Atienza offered Atibula P50,000 for Volume 260, which Atibula declined, leading to a confrontation. Atibula reported thi...

Facts:

Background of the Case

• Petitioners Ricardo L. Atienza and Alfredo A. Castro were employees of the Court of Appeals (CA), holding the positions of Budget Officer I and Utility Worker I, respectively.
• The case revolves around the alleged theft and falsification of Volume 266 of the CA Original Decisions, which contained a decision in the case of Mateo Fernando v. Heirs of D. Tuason, Inc.

Initial Events

• On March 20, 1995, Juanito Atibula, a Records Officer and Custodian of CA Original Decisions, was invited by Castro to attend Atienza’s birthday party. At the party, Atienza asked Atibula to assist a certain Dario in locating a specific CA decision.
• Atibula later observed Dario comparing pages of Volume 260 with discolored papers and marking them. Dario also examined Volumes 265 and 267.

Attempted Bribery

• On April 21, 1995, Atienza offered Atibula P50,000 to remove Volume 260 from the CA Reporteras Division. Atibula refused and reported the incident to his superiors, who instructed him to hide Volumes 260, 265, and 267.

Discovery of Missing Volume

• On May 9, 1995, Atibula discovered that Volume 266 was missing. Two days later, Atienza confronted Atibula, shouting, “Putang ina mo, Juaning, pinahirapan mo kami!”
• On May 18, 1995, Volume 266 was returned by Nelson de Castro, who claimed that Castro had asked him to deliver it. Upon inspection, Atibula found that two new documents had been inserted into the volume: a Resolution dated February 11, 1969, and a Decision dated April 16, 1970, both ostensibly penned by Justice Juan P. Enriquez.

Investigation and Findings

• The National Bureau of Investigation (NBI) conducted an investigation and found that the signatures on the inserted documents were forged. The NBI also discovered that the perpetrators had entered the CA Reporteras Division by removing an air conditioning unit and passing through a hole in the wall.
• A criminal complaint was filed against Atienza, Castro, and Dario for Robbery and Falsification of Public Documents.

Trial Court Proceedings

• The Regional Trial Court (RTC) found Atienza and Castro guilty of Robbery and Falsification of Public Documents, sentencing them to imprisonment and fines. The Court of Appeals (CA) affirmed the RTC’s decision.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Insufficiency of Circumstantial Evidence:

   • Circumstantial evidence must form an unbroken chain leading to a fair and reasonable conclusion of guilt. In this case, the evidence did not meet this standard.
   • Atienza’s bribery attempt and his confrontation with Atibula did not directly link him to the theft or falsification of Volume 266.
   • Castro’s alleged involvement was based on hearsay evidence, as Nelson de Castro, who claimed Castro returned the volume, was not presented in court for cross-examination.
   • There was no direct evidence or sufficient circumstantial evidence to prove that Atienza and Castro conspired to commit the crimes.

2. Jurisdictional Defect:

   • The RTC did not have jurisdiction over the Falsification of Public Documents case, as the crime is punishable by prision correccional, which falls under the jurisdiction of lower courts. This defect can be raised at any stage of the proceedings.

3. Presumption of Innocence:

   • The Constitution mandates that an accused is presumed innocent until proven guilty beyond reasonable doubt. The prosecution failed to meet this burden, and the circumstantial evidence presented was not sufficient to overcome the presumption of innocence.

Conclusion:

The Supreme Court acquitted Atienza and Castro due to insufficient evidence and jurisdictional defects. The Court emphasized that it is better to acquit ten guilty individuals than to convict one innocent person. The bail bonds posted by the petitioners were canceled and released.