Case Digest (G.R. No. L-18500)
Facts:
Pedro J. Amarille v. People of the Philippines, G.R. No. 256022, August 07, 2023, the Supreme Court Second Division, Lopez, J., writing for the Court.The criminal case arose from an Information charging Pedro J. Amarille with qualified theft for allegedly causing the taking of 200 coconut fruits (valued at PHP 2,000.00) from a coconut plantation in Pustan, Cabawan, Maribojoc, Bohol on or about November 4, 2011. Pedro pleaded not guilty at arraignment; pre-trial and trial on the merits then followed in the Regional Trial Court (RTC), Branch 2, Tagbilaran City.
At trial the prosecution presented evidence that the land where the coconuts grew was owned by Macario Jabines (as shown by Original Certificate of Title No. 25102) and that Pedro had the coconuts harvested. The defense presented testimony that Pedro instructed a neighbor, Daniel Albaran, to climb and gather coconuts because Pedro claimed ownership of the land; Daniel initially protested, referencing prior harvests for Hospicio Almonte (the deceased caretaker), but climbed the trees after Pedro assured he would answer any complaint. Pedro also presented Tax Declaration No. 2008-32-0008-00050 registered in the name of his late grandfather Eufemio Amarille and evidence that he had tilled the subject land since 1986. A barangay conference on November 9, 2011 produced an agreement that the harvested copra would be deposited at the barangay hall, but Pedro allegedly sold the copras and used the proceeds for his own consumption.
The RTC (Presiding Judge Jennifer Chava-Marcos) found Pedro guilty beyond reasonable doubt of qualified theft and sentenced him to an indeterminate term of imprisonment (Dec. 19, 2016 Decision). Pedro appealed to the Court of Appeals (CA). The CA (Special Nineteenth Division) affirmed the RTC’s conviction but modified the penalty to an indeterminate term of prision correccional (minimum) to prision mayor (maximum) (Decision dated December 13, 2019). The CA denied Pedro’s Motion for Reconsideration in a Resolution dated November 23, 2020.
Petitioner filed a Petition for Review on Certiorari under Rule 45 seeking reversal of the CA decision. The Supreme Court granted the petition in part: it...(Subscriber-Only)
Issues:
- Was Pedro J. Amarille proven guilty beyond reasonable doubt of qualified theft?
- If acquitted, is Pedro nevertheless liable to refund the proceeds of the copra sale and, if so, with wh...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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