Case Digest (G.R. No. 160188) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Aristotel Valenzuela y Natividad v. People of the Philippines, petitioner Aristotel Valenzuela y Natividad and co-accused Jovy Calderon were charged with theft by Information dated 20 May 1994 before the Regional Trial Court (RTC) of Quezon City, Branch 90. On 19 May 1994 at around 4:30 p.m., security guard Lorenzo Lago at the Super Sale Club in the SM North EDSA complex in Quezon City observed petitioner, wearing an RDU identification card, wheeling a pushcart loaded with cases of Tide Ultramatic detergent. Petitioner unloaded four cases in an open parking area, reentered the supermarket to fetch additional cartons, and again deposited them by the first load. He then hailed a taxi, and Calderon loaded all stolen cartons, valued at ₱12,090.00, into the vehicle. When Lago demanded a sales receipt, both accused fled on foot after a warning shot was fired; they were immediately apprehended and the merchandise recovered.At trial, petitioner and Calderon maintained they were inn
Case Digest (G.R. No. 160188) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Incident and Apprehension
- On 19 May 1994 at about 4:30 p.m., petitioner Aristotel Valenzuela and his companion Jovy Calderon were seen by SM security guard Lorenzo Lago removing multiple cases of “Tide Ultramatic” detergent from the Super Sale Club (SM North EDSA).
- They loaded four cases of Tide Ultramatic, one case of Ultra 25 g, and three other detergent cases (total value P12,090.00) into a taxi. Upon challenge, they fled; Lago fired a warning shot, and both were apprehended along with the stolen merchandise.
- Investigation, Trial and Appeals
- The duo was taken to the SM security office, then to the Baler PNP Station. Only Valenzuela and Calderon were charged with theft on 20 May 1994. They pleaded not guilty and claimed to be innocent bystanders; Valenzuela admitted employment as a “bundler.”
- On 1 February 2000, RTC Quezon City convicted them of consummated theft (2–7 years indeterminate sentence). Calderon’s appeal was deemed abandoned; Valenzuela appealed to the Court of Appeals, which affirmed the conviction on 19 June 2003. Valenzuela then filed this Petition for Review.
Issues:
- Factual–Legal Question
- Under the Revised Penal Code (RPC), did petitioner’s acts amount to consummated theft or only to frustrated theft?
- Should the “free disposition” criterion (from CA decisions in People v. DiAo and People v. Flores) be adopted to downgrade theft to its frustrated stage?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)