Case Digest (G.R. No. 214939)
Facts:
In Herman Medina v. People of the Philippines (G.R. No. 182648, June 17, 2015), petitioner Herman Medina, a mechanic in Santiago City, Isabela, was charged by information dated September 12, 2002, with simple theft under Article 308 in relation to Article 309(1) of the Revised Penal Code for allegedly taking, without owner’s consent, one alternator (₱5,000), one starter (₱5,000), one battery (₱2,500), and two tires with mag wheels (₱10,000) from Henry Lim’s Sangyong Korando Jeep between April 27 and September 4, 2002, amounting to ₱22,500. Lim had entrusted the damaged but running jeep to Medina for repair. When Lim’s sister, Purita, sent Danilo Beltran on September 4 to retrieve the vehicle for transfer to another shop, the missing parts were discovered. Medina admitted removal but claimed he installed them on Lim’s Isuzu pick-up with alleged owner’s consent. The Regional Trial Court (Branch 35, Santiago City) rendered a decision on March 31, 2005, finding Medina guilty beyondCase Digest (G.R. No. 214939)
Facts:
- Background of Parties and Subject Vehicle
- Henry Lim owned a Sangyong Korando Jeep, Plate No. WPC-207, involved in an accident; roof and door damaged but still serviceable.
- Lim engaged petitioner Herman Medina, a mechanic in Santiago City, to repair the jeep on April 27, 2002.
- Disappearance of Auto Parts
- After reasonable time without repairs, on September 4, 2002, Purita Lim sent Danilo Beltran to retrieve the jeep; Beltran found missing alternator, starter, battery, and two tires with mag wheels (total value ₱22,500).
- Medina admitted taking the parts and installing them on Lim’s Isuzu pick-up; Beltran recovered the jeep without the parts and towed it to his own shop.
- Criminal Proceedings
- On September 12, 2002, Purita Lim filed a complaint for simple theft; the City Prosecutor found probable cause and an Information was filed.
- At trial, prosecution witnesses: Beltran and Henry Lim; defense witnesses: Medina and barangay kagawad Angelina Tumamao. Defense failed to formally offer documentary evidence (acknowledgment receipt).
- RTC, Branch 35, Santiago City, convicted Medina of simple theft (Art. 308 in relation to Art. 309(1), RPC) on March 31, 2005 and sentenced him to prision correccional (3 y 6 m 21 d) to prision mayor (8 y 8 m 1 d) and indemnification of ₱22,500.
- CA affirmed the conviction (Jan. 7, 2008 Decision; Apr. 21, 2008 Resolution). Medina’s motion for reconsideration denied.
- Petition Before the Supreme Court
- Medina elevated the case via Rule 45 petition, alleging:
- Insufficiency of evidence (circumstantial, single circumstance).
- Prosecution relied on defense’s weakness (Alvario).
- Lack of furtive taking/unlawful asportation (consent implied, Abundo).
- Non-consideration of acknowledgment receipt (Sarraga exception).
- SC assigned Third Division and heard the petition.
Issues:
- Whether the evidence adduced (primarily testimony of Beltran) was sufficient to prove simple theft beyond reasonable doubt.
- Whether it was improper for the courts to rely on the weakness of the defense rather than the strength of the prosecution’s evidence.
- Whether the taking was with the consent or acquiescence of the owner, negating the element of furtive taking (asportation).
- Whether the acknowledgment receipt—identified but not formally offered—should have been admitted under exceptions to the Rules of Court and could exonerate Medina.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)