Case Digest (G.R. No. 175842)
Facts:
Nilo Macayan, Jr. y Malana v. People of the Philippines, G.R. No. 175842, March 18, 2015, the Supreme Court Second Division, Leonen, J., writing for the Court. Petitioner is Nilo Macayan, Jr.; respondent is the People of the Philippines.On February 20, 2001 an Information charged Macayan with robbery (Crim. Case No. Q-01-98670), alleging that on or about February 16, 2001 he intimidated private complainant Annie Uy Jao into delivering P4,000.00 (marked bills) during an arranged meeting, contrary to Article 293 of the Revised Penal Code. The case was tried before Branch 101, Regional Trial Court (RTC) of Quezon City.
At trial the prosecution presented Jao, Rodrigo Mapoy (team leader of NBI operatives who conducted an entrapment), and a forensic chemist; Macayan testified for the defense and introduced minutes/constancias from his separate illegal dismissal case (NLRC-NCR Case No. 00-09-05057-00). Jao testified that Macayan threatened to harm or kidnap her family to extort P200,000, set a rendezvous, and accepted an envelope containing marked bills; NBI operatives arrested Macayan at a McDonald’s after he partly exposed the marked bills. The defense emphasized that Jao did not attend the NLRC conferences (her secretary Marjorie Angel represented her), that Angel was not presented as a witness, and that the identity of the caller who allegedly renewed the threats rested only on being addressed as “Madam.”
On November 15, 2002, the RTC found Macayan guilty beyond reasonable doubt of robbery and imposed an indeterminate sentence (minimum: 4 months + 1 day arresto mayor; maximum: 4 years, 2 months + 1 day prisión correccional), ordering return of the marked P4,000 to Jao after finality. Macayan appealed to the Court of Appeals (CA); the Office of the Solicitor General (OSG) at the appellate stage filed a Manifestation and Motion in Lieu of Appellee’s Brief recommending acquittal, stressing deficiencies in proof of intimidation and identity of the caller.
On July 31, 2006 the CA Tenth Division affirmed the RTC decision but increased the penalty (indeterminate sentence of 1 year, 7 months, 11 days prisión correccional minimum to 6 years, 1 month, 11 days prisión mayor maximum). The CA reasoned that Jao’s lone testimony was credible and that attendance constancias were not necessa...(Pro-only)
Issues:
- Whether petitioner’s guilt beyond reasonable doubt for robbery was established. ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)