Case Digest (G.R. No. 234228) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Juanito Gallano y Obrar v. People of the Philippines (G.R. No. 230147, February 21, 2024), petitioner Juanito Gallano y Obrar was charged with illegal possession and use of a counterfeit ₱1,000.00 bill (serial no. LB685736) at the Lotto outlet owned by George Arellano, located in Arellano Building, Rizal Street, Sorsogon City, on August 11, 2011 at about 8:05 p.m. The Information alleged that petitioner knowingly possessed and used the fake bank note to place a bet. Janet Janoras, the teller, first refused the bill for lack of change and informed petitioner it was counterfeit. Petitioner left briefly, returned, and again offered the same bill. Arellano used a UV scanner, confirmed the absence of a genuine security thread, and reported the incident to the police. The counterfeit was confiscated, endorsed to the Bangko Sentral ng Pilipinas (BSP), and certified counterfeit on August 16, 2011. Petitioner pleaded not guilty, and on January 19, 2015, Branch 53 of the Regional Trial... Case Digest (G.R. No. 234228) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Proceedings
- Petitioner Juanito Gallano y Obrar filed a Petition for Review on Certiorari under Rule 45, challenging the Court of Appeals’ Decision (August 31, 2016) and Resolution (January 5, 2017) in CA-G.R.CR No. 37787.
- He was charged with illegal possession and use of a counterfeit PHP 1,000 bill under Article 168 in relation to Article 166 of the Revised Penal Code.
- Prosecution’s Version
- On August 11, 2011 at about 8:05 p.m., petitioner attempted to pay for a lotto ticket at George Arellano’s outlet in Sorsogon City using a PHP 1,000 bill (serial LB685736). Teller Janet Janoras detected it was fake, informed petitioner, who left briefly then returned and again tendered the same bill.
- Arellano examined the bill under a UV scanner, confirmed absence of security threads, and called the police. The counterfeit bill was confiscated, an evidence custodian documented chain of custody, scanned it, and private complainant sent the bill to the Bangko Sentral ng Pilipinas (BSP). BSP’s Certification (August 16, 2011) confirmed the bill was counterfeit.
- Defense’s Version
- Petitioner testified he was initially refused due to lack of change, then retrieved PHP 30 from his motorcycle to pay. He voluntarily handed the PHP 1,000 bill back for re-examination after being told it might be fake and did not intend to use it.
- His brother Andres Gallano testified he gave petitioner the bill on August 9, 2011, unaware it was counterfeit.
- Trial and Appellate Decisions
- RTC Branch 53 convicted petitioner (January 19, 2015) of violating Art. 168/166, sentenced him to 3 years, prision correccional medium to 6 years 1 day, prision mayor minimum, plus PHP 5,000 fine.
- The Court of Appeals affirmed with modification (August 31, 2016), raising the indeterminate penalty to 8 years 1 day to 10 years 8 months 1 day, prision mayor. Reconsideration was denied (January 5, 2017).
Issues:
- Whether the Court of Appeals erred in affirming petitioner’s conviction for illegal possession and use of false treasury notes under Article 168 in relation to Article 166.
- Whether the prosecution proved petitioner’s knowledge of the bill’s counterfeit nature and intent to use it (mens rea).
- Whether the non-presentation of the actual counterfeit bill undermines proof of corpus delicti.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)