Case Digest (G.R. No. 117442-43) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Arsenia B. Garcia v. Honorable Court of Appeals and the People of the Philippines (G.R. No. 157171, decided March 14, 2006), petitioner Arsenia B. Garcia served as Chairperson of the Municipal Board of Canvassers of Alaminos City, Pangasinan during the May 8, 1995 senatorial elections. Private complainant Aquilino Q. Pimentel, Jr. alleged that, on May 11, 1995, Garcia conspired with other board members and tabulators to reduce his total votes from 6,998 (as shown in the sealed Statements of Votes from 159 precincts) to 1,921 in the final Certificate of Canvass (COC No. 436156). On March 30, 1998, an information was filed in the Regional Trial Court (RTC) of Alaminos City, Branch 54, charging Garcia under Section 27(b) of Republic Act No. 6646 for unlawfully decreasing Pimentel’s votes. In a September 11, 2000 decision, the RTC acquitted all co-accused for insufficiency of evidence but found Garcia guilty beyond reasonable doubt, imposing an indeterminate sentence of six month Case Digest (G.R. No. 117442-43) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- In the May 8, 1995 senatorial elections, private complainant Aquilino Q. Pimentel, Jr. ran for the Senate.
- A complaint‐affidavit by Pimentel alleged that during the canvassing on May 11, 1995 in Alaminos City, Pangasinan, Municipal Board of Canvassers members Arsenia B. Garcia (Chairman), Renato R. Viray (Secretary), Herminio R. Romero (Member), and tabulators Rachel Palisoc and Francisca de Vera conspired to decrease Pimentel’s votes from 6,998 (per precinct statements) to 1,921 (per Certificate of Canvass), a shortfall of 5,077 votes, in violation of Section 27(b) of R.A. 6646.
- Procedural History
- The RTC of Alaminos City (Br. 54) acquitted all accused except Garcia, convicting her under R.A. 6646 § 27(b): imposed maximum 6 years, minimum 6 months (indeterminate), disqualification from office, and deprivation of suffrage.
- The Court of Appeals (CA‐G.R. CR No. 24547) affirmed with modification, raising the minimum penalty from 6 months to 1 year; denied reconsideration.
- Garcia petitioned the Supreme Court, assigning errors:
- CA’s reliance on speculation as to who decreased the votes.
- Alleged failure to produce adding‐machine tapes at trial.
- Assertion that entering the reduced figure was Viray’s duty, not Garcia’s.
- Denial of willfulness or intent to decrease the votes.
Issues:
- Whether a violation of Section 27(b), R.A. 6646 is mala in se or mala prohibita.
- Whether good faith or lack of criminal intent can constitute a valid defense.
- Whether the evidence sustains a finding that Garcia willfully and unlawfully decreased Pimentel’s votes.
- Whether the CA properly rejected Garcia’s procedural and evidentiary objections (e.g., non-production of tapes).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)