Case Digest (G.R. No. 86220) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Bonifacio Ciobal y Pabrua, Eusebio Ebreo y Ringor, Ester Pajimola y Ebreo, Ricardo Lim, Ricardo Miranda and Eddie Pajimola (G.R. No. 86220, April 20, 1990), six employees of Ben’s Petron Station Service Center in San Fernando, La Union were charged with qualified theft. An information dated February 15, 1985 alleged that between December 1980 and subsequent dates, the accused, abusing their positions of trust, tampered with the gasoline pump meters and diverted sales totaling ₱118,855.21. Employer‐manager Benjamin M. Galvez discovered shortages on May 27, 1981, traced discrepancies to meter adjustments, recovered bank deposit slips from Bonifacio Ciobal, and secured admissions from several employees. The trial court denied motions for reconsideration, new trial and to admit additional evidence under amended Rule 119, §15, and, on May 5, 1988, convicted all six appellants as principals of qualified theft, sentencing them to reclusion perpetua, ord Case Digest (G.R. No. 86220) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Criminal information and charge
- On February 15, 1985, an information was filed in the Regional Trial Court of San Fernando, La Union, charging six employees—Bonifacio Ciobal, Eusebio Ebreo, Ester Pajimola, Ricardo Lim, Ricardo Miranda, and Eddie Pajimola—with qualified theft.
- The accused were alleged to have conspired to tamper with the gasoline pump meter at Bens Petron Service Center, causing a loss of ₱118,855.21 to their employer, Benjamin M. Galvez.
- Trial court proceedings
- The trial court found all six guilty beyond reasonable doubt as principals and sentenced them to reclusion perpetua, ordering joint and several indemnification of ₱118,855.21.
- May–September 1988 motions:
- Motion for reconsideration on penalty (denied).
- Motion for new trial and to admit additional evidence (denied).
- Motion to avail of amended Rule 119, Sec. 15 (denied).
- Appeal and appellate issues
- Notice of appeal filed November 17, 1988.
- Assigned errors: sufficiency of evidence; conspiracy; penalty imposition; denial of motions; non-application of amended Rule 119, Sec. 15.
- Prosecution’s key evidence
- Sole, uncorroborated testimony of offended party Benjamin Galvez detailing meter reading discrepancies, admissions by some accused, and auditor’s loss computation.
- Auditor Reynaldo Dyquiangco’s report estimating loss at ₱118,855.21, rejected by trial court as hearsay; underlying documents missing.
- Supplemental matters
- Solicitor General’s concession that penalty range under the Indeterminate Sentence Law was misapplied.
- Allegation that the accused paid ₱3,000 each to Judge Francisco Collado, prompting a recommended investigation of judicial integrity.
Issues:
- Whether conviction can rest on the sole, uncorroborated testimony of an interested witness.
- Whether conspiracy was adequately proven by independent evidence.
- Whether admissions by some accused were admissible against co-accused under:
- Rule 130, Sec. 22 (party admissions) vs. Sec. 25 (third-party admissions).
- Sec. 23 (admission by silence).
- Sec. 27 (admission by co-conspirator).
- Whether the prosecution proved the nature and correct amount of the alleged loss, an essential element of qualified theft.
- Whether the penalty of reclusion perpetua was properly imposed under the Indeterminate Sentence Law and the 1987 Constitution.
- Whether the trial court erred in denying:
- The motion for new trial.
- The motion to admit evidence under amended Rule 119, Sec. 15.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)