G.R. No. 212942 - Estrella y Gili vs. People

An Information dated June 29, 1999 charged petitioner Benito Estrella y Gili with violating Section 2, PD 1612 (“Anti-Fencing Law”) for acquiring, possessing, selling and disposing of three (3) five-gallon pails of Skydrol LD-4 hydraulic fluid (Manufacturer Lot No. IAI/Y2.4/300/98USA/M-4122), valued at ₱27,000, knowing or having reason to know it was stolen from Philippine Airlines (PAL).
Upon arraignment, petitioner pleaded not guilty and trial on the merits ensued before RTC Branch 119, Pasay City.

Elvis Yao, PAL Vice-President for Fuel Management, testified that PAL was the sole importer of five-gallon Skydrol from Solutia, Inc. in the U.S., and that in 1998 PAL noted an anomalous increase in its Skydrol consumption despite downsizing its fleet. Investigation revealed Aerojam Supply and Trading (owned by petitioner) was selling five-gallon pails of Skydrol to Air Philippines at suspiciously low prices.
PAL provided PNP-CIDG operatives with sample pails, lot numbers and delivery reports. Surveillance on June 19 and 22, 1999, led by PO3 Raul Bolido, photographed and observed petitioner delivering Skydrol at Villamor Airbase and Air Philippines hangar. On June 22, operatives apprehended petitioner with three pails; he failed to produce ownership documents, pointing instead to an absent “Jupel.” PAL confirmed the confiscated pails were part of its stock.

Petitioner testified he was a 23-year Aerojam salesman of aviation supplies. He claimed he sourced Skydrol from International Business Aviation, Inc. (IBAI), which had closed, purchasing 20 pails at ₱8,000–9,000 each and selling at ₱10,000. He asserted he was summoned by “Janet” of Air Philippines and was framed during police interception.
Alvin Ygona of Global Air Tech (former Avial, Inc. representative) testified that Skydrol lot numbers were not unique to PAL and that Solutia had multiple Asia-Pacific distributors and brokers.

RTC Decision dated February 15, 2010 convicted petitioner of fencing under PD 1612, sentencing him to prision mayor (10 years + 1 day to 10 years 8 months).
On appeal, the CA in Decision November 20, 2013, affirmed the conviction, finding petitioner knew or should have known the Skydrol was stolen and intended to profit. A Motion for Reconsideration was denied on June 3, 2014.

Whether the CA erred in affirming petitioner’s conviction for fencing under Section 2, PD 1612.
Whether petitioner’s defenses—fabrication of evidence by PAL, denial of guilt, and alleged frame-up—negate the prosecution’s proof beyond reasonable doubt.
Whether the petition raises only questions of law, as required under Rule 45.