Case Digest (G.R. No. 200751)
Facts:
Monico Ligtas v. People of the Philippines, G.R. No. 200751, August 17, 2015, Supreme Court Second Division, Leonen, J., writing for the Court. Petitioner Monico Ligtas was charged with theft under Article 308 of the Revised Penal Code for allegedly harvesting 1,000 kilos of abaca from the plantation of private complainant Anecita Pacate on June 29, 2000. The Information alleged that Ligtas entered the plantation and feloniously harvested the abaca without the owner’s consent, valued at Php29,000. Ligtas pleaded not guilty.At the Regional Trial Court (Branch 39, Sogod, Southern Leyte), the prosecution presented five witnesses who identified Ligtas as the harvester; the defense presented Ligtas and two witnesses who testified that Ligtas was a tenant entitled to harvest and who asserted an alibi. Despite the defense, the trial court, in a Decision dated August 16, 2006, found Ligtas guilty beyond reasonable doubt, imposed the indeterminate penalty and ordered indemnities and damages.
Concurrently, Ligtas had filed a separate complaint before the Department of Agrarian Reform Adjudication Board (DARAB) — DARAB Case No. VIII-319-SL-2000 — for maintenance of peaceful possession. On January 22, 2002, the DARAB rendered a Decision finding Ligtas a bona fide tenant and ordering that he be maintained in peaceful possession; the DARAB award included P5,000 for litigation expenses. The DARAB decision attained finality as no appeal by private complainant was shown in the record. Records further show that the DARAB Decision was considered by the trial court and the Court of Appeals without objection by the People, although the exact time it was formally offered in evidence is not clear.
The Court of Appeals (Eighteenth Division, CA-G.R. CEB-CR No. 00482) affirmed the trial court’s conviction in a Decision dated March 16, 2010, holding that Ligtas failed to prove the essential elements of tenancy and that the elements of theft were established; the CA ruled the DARAB determination to be irrelevant, citing precedent that such findings are preliminary. The CA denied Ligtas’ Motion for Reconsideration in a Resolution dated February 2, 2012.
Thereafter, Ligtas filed a Petition for Review on Certiorari under Rule 45 of the...(Pro-only)
Issues:
- May questions of fact be reviewed in a petition for review on certiorari under Rule 45 of the Rules of Court?
- Is a DARAB decision declaring a person a bona fide tenant conclusive or judicially notice-worthy in a criminal case for theft?
- Did the Court of Appeals err in affirming petitioner’s conviction for theft under Article 308 of the Revised Penal Code in light ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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