Case Digest (G.R. No. 209386) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mel Carpizo Candelaria v. The People of the Philippines (G.R. No. 209386, December 8, 2014), private complainant Jessielyn Valera Lao, owner of United Oil Petroleum Phils. (Unioil), engaged petitioner Mel Carpizo Candelaria as a truck driver to deliver 14,000 liters of diesel fuel valued at ₱497,000.00 to Viron Transit Corporation in Laon Laan, Manila on August 23, 2006. Candelaria and his helper, Mario Romano, loaded the fuel onto truck plate PTA-945 and departed at 12:50 PM. At around 5:00 PM, Viron reported non-receipt of the shipment. Lao’s attempts to reach Candelaria failed. Later that evening, Romano alone returned and alleged that Candelaria threatened him with a balisong, prompting a report to the Manila Police District and Camp Crame. Days later, National Bureau of Investigation agents found the abandoned truck in Calamba, Laguna, utterly drained of its load. Lao filed a complaint for Qualified Theft (Crim. Case No. 08-259004). The Regional Trial Court of Manila, Br Case Digest (G.R. No. 209386) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract and Loading
- On August 23, 2006, Viron Transit Corporation ordered 14,000 liters of diesel fuel from United Oil Petroleum Phils. (Unioil), owned by Jessielyn Valera Lao, valued at ₱497,000.00.
- Petitioner Mel Carpizo Candelaria, a Unioil truck driver, with helper Mario Romano, loaded the diesel into lorry PTA-945 at 12:50 PM for delivery to Viron at Laon Laan, Manila.
- Non-Delivery and Retrieval
- Around 5:00 PM, Viron reported non-receipt; Lao’s calls to Candelaria went unanswered.
- At approximately 6:00 PM, Romano returned alone, claiming Candelaria threatened him with a balisong; Lao reported the incident to MPD and Camp Crame.
- A few days later, NBI agents found the abandoned truck in Calamba, Laguna, emptied of diesel.
- Litigation History
- Lao filed a qualified theft complaint (Crim. Case No. 08-259004). RTC Branch 21 Manila convicted Candelaria on June 21, 2011—imposing 14 years & 1 day to 17 years & 4 months reclusion temporal and indemnity of ₱497,000.00.
- Candelaria appealed; the Court of Appeals on January 31, 2013 affirmed conviction but reduced indemnity to ₱14,000.00; motion for reconsideration denied September 3, 2013.
Issues:
- Guilt by Circumstantial Evidence
- Whether the Court of Appeals correctly convicted Candelaria of Qualified Theft based solely on circumstantial evidence.
- Whether the valuation of the stolen diesel fuel was properly determined for penalty purposes.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)