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:

Employment and Initial Interaction

• Petitioners, Ricardo L. Atienza and Alfredo A. Castro, were employees of the Court of Appeals (CA), assigned respectively as Budget Officer I and Utility Worker I in the Budget Division.
• Their positions and access to the CA’s records set the stage for the later events, with Atienza taking a leading role in the alleged misconduct.

The Birthday Party and Document Retrieval

• On March 20, 1995, Atienza hosted a birthday party at which he introduced Records Officer Juanito Atibula to a man identified as Dario.
• Atienza instructed Atibula to assist Dario in searching for a decision in the “Mateo Fernando v. Heirs of D. Tuason, Inc.” case, located in Volume 260 of the CA Original Decisions.
• While Dario examined the volume, Atibula noted unusual behavior, including check marks on pages and a comparison with discolored papers.

Subsequent Incidents and the Missing Volume

• On March 24, 1995, after office hours, Dario reappeared outside the CA compound and requested Atibula to insert a Decision dated September 26, 1968, into one of the volumes—a request that Atibula refused.
• On April 21, 1995, Atienza offered Atibula P50,000.00 in exchange for Volume 260, but Atibula declined, leading to a heated verbal exchange that was reported to a superior.
• Shortly thereafter, Atibula discovered that Volume 266, covering part of 1969, was missing, prompting him to immediately report the loss to his superiors.

Discovery of Alterations and the Falsified Documents

• On May 18, 1995, Nelson de Castro, a Clerk IV, delivered a gift-wrapped package containing the missing Volume 266, allegedly at the behest of Castro.
• Upon inspection, Atibula noted that Volume 266 contained two new documents not recorded in the official compilation:
• A Resolution dated February 11, 1969, purportedly drafted by Associate Justice Juan P. Enriquez with concurrences from Justices Magno S. Gatmaitan and Edilberto Soriano.
• A Decision dated April 16, 1970, also ostensibly by Justice Enriquez and concurred in by Associate Justices Jesus Y. Perez and Jose M. Mendoza, amending an earlier decision from September 26, 1968.
• The authenticity of these documents was questioned when laboratory analysis and comparative examination by the NBI revealed alterations and forged signatures.

Physical Evidence and Entry into the CA Premises

• An inspection in July 1995 of the air-conditioning unit and supporting structure at the CA Reporteras Division disclosed rust, corrosion, and a broken wall segment.
• These findings supported the theory that the perpetrators had gained unauthorized entry by exploiting a structural defect, thereby facilitating the removal and subsequent tampering of Volume 266.

Criminal Charges and Trial Developments

• Following the discovery of the altered volume, the NBI and the Office of the Ombudsman filed criminal complaints charging Atienza, Castro, and Dario with:
• Falsification of Public Document (combining provisions of Article 172(1) and Article 171(6) of the Revised Penal Code)
• Robbery under Article 299(a)(1) of the Revised Penal Code
• Violations of Section 3(a) of Republic Act No. 3019 and Section 8 of Republic Act No. 6713 (the latter charges were later dismissed for insufficiency of evidence).
• Petitioners posted bail and pleaded not guilty at the Regional Trial Court (RTC) level, while Dario remained at large.
• The RTC, in its June 8, 2006 decision, found petitioners guilty beyond reasonable doubt, sentencing them to prision correccional with specific terms for robbery and falsification charges.
• Castro and Atienza’s actions, including the bribery attempt, the handling of the missing volume, and the subsequent tampering with official records, were cited as evidence of a community of criminal design.

Appellate Proceedings

• On November 28, 2008, the Court of Appeals (CA) affirmed the RTC’s judgment, relying heavily on circumstantial evidence and inferences drawn from the sequence of events.
• Petitioners, disagreeing with the conclusions drawn by both the RTC and CA, raised a motion for reconsideration—which was denied—leading to their petition for review on certiorari before the higher court.

Issue:

Sufficiency of Circumstantial Evidence

• Whether the circumstantial evidence presented by the prosecution forms an unbroken chain sufficiently establishing the guilt of petitioners beyond a reasonable doubt.

Evaluation of the Alleged Conspiracy

• Whether the actions of Castro and Atienza, including the bribery attempt and handling of Volume 266, amount to a concerted conspiracy to commit robbery and falsification.

Assessment of Hearsay and Testimonial Evidence

• Whether reliance on statements—such as that of Nelson de Castro’s affidavit—constitutes admissible and probative evidence to link petitioners to the crimes.

Jurisdictional Concerns on the Falsification Case

• Whether the RTC had jurisdiction to try the falsification charge under Article 172(1) (in relation to Article 171(6) of the RPC), given that this offense falls under the exclusive jurisdiction of lower courts as mandated by the Judiciary Reorganization Act of 1980 (as amended by RA 7691).

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)