G.R. No. L-46484 - Mendoza vs. People

On November 28, 1965, 310 bags of American rice valued at P5,908.60, owned by the Rice and Corn Administration (RCA), were unloaded from a vessel at Pier 5, South Harbor, Manila.
The cargo was loaded onto a truck bearing plate No. TH-2296, owned by Yellow Ball Freight Lines, with Ponciano Reponte as the driver and Wilfredo Escopin as his helper (“pahinante”).

The rice was intended for delivery to RCA Warehouse No. 3 at Pureza Street, Manila, under the custody of Emilio Rosella.
Instead of following the designated delivery route, the truck driver and his helper, together with an individual identified as Frank, diverted the cargo to the grocery store of Leonardo Mendoza at 160 A. Bonifacio, Balintawak, Quezon City.
Several bags of rice had already been unloaded at Mendoza’s grocery store when police operatives arrived.

Upon the arrival of police, Reponte, Escopin, and Mendoza were arrested; Frank managed to elude arrest and remains at large.
Following a due investigation, the Assistant City Fiscal of Quezon City filed an information for qualified theft in the Court of First Instance of Rizal at Quezon City.
The information charged Reponte, Escopin, and John Doe alias Frank as principals and Leonardo Mendoza as an accessory after the fact for “purchasing and receiving from the principal the said bags of rice, thereby aiding the accused to profit from the effects of the crime.”

At arraignment, Reponte and Escopin pleaded not guilty to the charge; however, Reponte later withdrew his plea and was rearraigned, eventually pleading guilty to simple theft.
Reponte was sentenced to one (1) year of prision correccional and ordered to pay the costs. The lower court did not impose an indemnity as the stolen rice had been recovered.
During the trial, Escopin moved to dismiss the charge against him. His motion was denied by the lower court but, on September 14, 1966, the court rendered a decision acquitting him of qualified theft based on a lack of evidence of a conspiracy with Reponte.

The trial against Leonardo Mendoza proceeded after the resolution of the proceedings involving the other accused.
On July 7, 1968, the lower court found Mendoza guilty beyond reasonable doubt as an accessory after the fact in the crime of qualified theft, imposing an indeterminate penalty ranging from four (4) months and twenty (20) days of arresto mayor (minimum) to one (1) year, eight (8) months and twenty-one (21) days of prision correccional (maximum).
The judgment noted that no indemnity was payable as the stolen goods were recovered, and Mendoza was ordered to pay the costs as well.

The Court of Appeals, upon review, affirmed the lower court’s judgment in toto with costs against Leonardo Mendoza, finding the evidence and applicable law supportive of the conviction.
Mendoza, through his petition for review on certiorari, contended that the prosecution had failed to establish the commission of the crime of qualified theft and that his conviction as an accessory after the fact was based solely on presumption and suspicion.
He argued that his constitutional right to be presumed innocent until proven guilty had been violated.
Mendoza accepted the Solicitor General’s recommendation that if proven guilty, he should be charged only as an accessory to the crime of simple theft.

Reponte’s testimony revealed that there was a prior understanding among the accused, specifically that the stolen RCA rice was to be sold to Mendoza.
Although Mendoza admitted that the rice was brought to his store “merely for deposit,” this admission did not negate Reponte’s account.
The lower court and the Court of Appeals relied on both direct and circumstantial evidence—such as the fact that Mendoza, as an RCA retailer, had sufficient knowledge of how RCA rice is distributed—which suggested that accepting a large quantity of rice from someone he barely knew was not in line with routine deposit practices.
Additional observations noted that Mendoza had agreed with Frank to “deposit” the rice at his premises, indicating a willingness to assist in profiting from the stolen goods.

Whether the prosecution established beyond reasonable doubt that qualified theft was committed, particularly concerning the qualifications under Article 310 of the Revised Penal Code.
Whether Leonardo Mendoza’s actions, including receiving such a large quantity of rice at his premises, demonstrate sufficient knowledge of its stolen nature to render him liable as an accessory after the fact.
Whether the circumstantial evidence—including the testimony of Reponte and Mendoza’s behavior as an RCA retailer—adequately satisfies the burden of proof required for accessory liability.
Whether it was proper to convict Mendoza as an accessory to qualified theft or simply as an accessory to the crime of theft under Article 308, given the absence of direct evidence of his knowledge of the underlying crime.