G.R. No. 170415 - People vs. Castro

Appellant Jesus Castro, a longtime employee of Roman Cruz’s trucking business, was charged and found guilty of qualified theft by the RTC of Baguio City (Criminal Case No. 13963-R).
The charge arose from allegations that, sometime in August 1993, as shop supervisor, Castro unlawfully removed from Cruz’s storeroom a set of spare parts (including a crank shaft, cylinder head assembly, pistons, piston rings, connecting rod bearings, main bearings, and an overhauling gasket) valued at ₱64,000.
The charge was based on the accused’s abuse of trust, having access to the storeroom and allegedly misappropriating inventory for personal gain.

Roman Cruz, owner of Romy’s Freight Services, had operated his trucking business for decades with a steady inventory of spare parts kept in his storeroom.
In 1993, Cruz purchased spare parts on March 22, July 27, and August 23, which were then allegedly stored in the shop.
In December 1993, an inventory revealed that the spare parts corresponding to those purchases were missing.
When confronted about the loss, Castro offered a dubious explanation, and other workers denied any knowledge of such an occurrence.

Cruz, who had employed Castro since 1975 and later promoted him to shop supervisor, stated that the inventory loss involved spare parts purchased earlier that year.
Cruz indicated that Castro was one of the few holders of the storeroom keys and trusted with accessing the inventory.

Torres, a neighbor and business associate, initially claimed that Castro was collecting a loan and later indicated that Castro delivered spare parts to his associate Romeo Inso.
Romeo Inso confirmed receiving the spare parts from Castro.
Rosita Crispin, who eventually bought the spare parts, testified that negotiations took place with Castro, including a down payment.

Castro admitted to having sold spare parts through Inso and Torres, but contended that the parts did not originate from Cruz’s storeroom.
He claimed that in August 1993, at Cruz’s request for repairs on Torres’ vehicle, he sought spare parts from a supplier, Dominador Uson, and later purchased necessary parts from Angel Boleyley.
Castro maintained that his regular protocol, as shop supervisor, was to use spare parts immediately for repairing trucks without storing them long term.
He further substantiated his claim through testimony by defense witnesses, including Boleyley and mechanic Dominador Viloria, asserting that replacement parts were bought only when a defect was identified.

The RTC found Castro guilty of qualified theft based on circumstantial evidence enumerated in its decision.

The prosecution pointed to the matching of the missing spare parts with those purportedly delivered to Inso and subsequently negotiated with Rosita Crispin.
The trial court emphasized factors such as Castro’s exclusive custodianship of the storeroom keys and his role in dispatching trucks for repairs.

Castro raised several assignments of error in the appellate proceedings, challenging:

The Court of Appeals ultimately affirmed the trial court’s decision, increasing the penalty to reclusion perpetua.

The Supreme Court reviewed the case’s circumstantial evidence and the legal standards for convicting an accused on such evidence.
It reiterated the requirement that circumstantial evidence must form an “unbroken chain” free of any plausible alternative hypothesis and prove guilt beyond reasonable doubt.
Noting several inconsistencies and gaps in the prosecution’s circumstantial evidence—including the long lapse between purchase and discovery of the loss, the possibility that the spare parts could have been used for repairs, and the inability to conclusively link the parts delivered to Inso with those missing from the storeroom—the Court found that the prosecution failed to discharge its burden.
Consequently, the Supreme Court reversed the appellate decision and acquitted Castro of the charge of qualified theft.

Whether the chain of circumstances presented by the prosecution was complete, consistent, and capable of excluding any hypothesis of innocence.
Whether the time lapse between the purchase and the inventory loss undermined the reliability of the circumstantial evidence linking the spare parts.

The propriety of giving full faith and credence to the testimonies of prosecution witnesses (Torres, Inso, and Cruz) despite their potential partiality or bias.
The evaluation of conflicting accounts and whether the defense witnesses’ testimonies were unfairly discounted.

Whether the spare parts sold by Castro, as testified by him and corroborated by defense witnesses, were indeed drawn from Cruz’s storeroom or sourced independently from a supplier (Boleyley).

Whether the prosecution managed to prove all elements of qualified theft beyond a reasonable doubt.
The proper application of the rule on circumstantial evidence, specifically, whether each required condition for a conviction was satisfied.