Case Digest (G.R. No. 256022) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pedro J. Amarille v. People of the Philippines (G.R. No. 256022, August 7, 2023), the respondent – the People of the Philippines – charged petitioner Pedro J. Amarille with qualified theft under Article 310 of the Revised Penal Code for taking 200 coconut fruits valued at ₱2,000.00 from the plantation of Macario Jabines in Pustan, Cabawan, Maribojoc, Bohol, on the morning of November 4, 2011. Pedro enlisted laborer Daniel Albaran to climb 18 trees and gather the coconuts, assuring him he would answer any complaints. On November 7, the Jabines heirs learned of the harvest and filed a complaint; a barangay conference on November 9 produced an agreement that Pedro would deposit the copra, but he instead sold it for personal consumption. The Regional Trial Court (RTC) found Pedro guilty beyond reasonable doubt of qualified theft and sentenced him to an indeterminate penalty of prision mayor. On appeal, the Court of Appeals (CA) affirmed with modification, reducing the penalty to Case Digest (G.R. No. 256022) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Information and Arraignment
- On November 4, 2011, in Maribojoc, Bohol, Pedro J. Amarille (“Pedro”) requested Daniel Albaran to climb and harvest mature coconuts from a plantation registered under OCT No. 25102 in the names of the heirs of Macario Jabines.
- Albaran initially hesitated, knowing the property was cared for by the late Hospicio Almonte, but Pedro assured he would answer any complaint; Albaran then climbed 18 trees and gathered 200 coconuts.
- Barangay Conference and Agreement
- On November 7, Noel Jabines, Macario’s son, learned of the harvest and reported it to the barangay and police; a barangay conference was held on November 9, 2011.
- Pedro admitted gathering and converting the fruits into copra but insisted his grandfather, Eufemio Amarille, owned the land. The parties agreed he would cease harvesting and deposit the copra; instead, Pedro sold the copra and used the proceeds personally.
- Lower Court Decisions
- RTC, Criminal Case No. 15822 (Dec. 19, 2016): Found Pedro guilty of qualified theft under Art. 310 RPC; sentenced him to 8 years 1 day prision mayor (medium) to 14 years 8 months 1 day reclusion temporal (medium).
- CA, CA-G.R. CR No. 03080 (Dec. 13, 2019; Resolution Nov. 23, 2020): Affirmed with modification; imposed 2 years 4 months 1 day prision correccional (minimum) to 6 years 1 day prision mayor (maximum). Reconsideration denied.
- Pedro moved for relief via Rule 45 petition before the Supreme Court.
Issues:
- Guilt of Qualified Theft
- Whether Pedro was proven guilty beyond reasonable doubt of qualified theft of coconuts under Art. 310, RPC.
- Scope of Rule 45 Review
- Whether the Supreme Court may reexamine factual findings under exceptions to the prohibition on reviewing questions of fact in a Rule 45 petition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)