Case Digest (G.R. No. 234023)
Facts:
People of the Philippines v. Jennie Manlao y Laquila, G.R. No. 234023, September 03, 2018, the Supreme Court Second Division, Perlas-Bernabe, J., writing for the Court.
The accused-appellant is Jennie Manlao y Laquila (Jennie); the private complainant and injured party is Carmel Ace Quimpo‑Villaraza (Carmel). An Information was filed in the Regional Trial Court (RTC) of Quezon City charging Jennie with Qualified Theft under Article 310 in relation to Article 309 of the Revised Penal Code for the alleged theft on July 1, 2011 of numerous watches, diamond and pearl jewelry valued in the Information at P1,849,000.00.
Carmel testified that she hired Jennie as a housemaid in February 2011 and had expressly warned her and other household help not to entertain callers purporting to be her in the event of an emergency. On July 1, 2011, another maid, Geralyn Noynay, observed Jennie speaking on the house phone and crying; Geralyn followed Jennie upstairs and caught her prying open a bathroom drawer with implements and later saw Jennie remove jewelry from the drawer. Jennie left the house with the jewelry; she was later found by village guards and, when confronted by Carmel and her husband, allegedly admitted taking the items and stated she was instructed by callers to look for dollars and later to take the jewelry and deliver them to a woman. Jennie denied criminal intent at trial, asserting she was deceived by persons posing as Carmel who directed her by phone to fetch money or jewelry for delivery.
The RTC, in a Decision dated June 19, 2014, found Jennie guilty beyond reasonable doubt of Qualified Theft, sentenced her to reclusion perpetua, and ordered restitution of P1,189,000.00 (the RTC adjusted Carmel’s estimated aggregate value downward from the Information’s figures). Jennie appealed to the Court of Appeals (CA). In a Decision dated May 1...(Pro-only)
Issues:
- Is Jennie guilty beyond reasonable doubt of Qualified Theft under Article 310 in relation to Article 309 of the Revised Penal Code?
- If guilty, what is the proper penalty and monetary award to be imposed, considering post‑offense ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)