G.R. No. 166995 - Villareal vs. Aliga

On October 31, 1996, an Information was filed against Consuelo C. Aliga (respondent), then accountant of Dentrade Inc., accusing her of Qualified Theft through Falsification of Commercial Document.
The charge alleged that on October 30, 1996, Aliga unlawfully altered a check originally issued by Dennis T. Villareal, president of Dentrade Inc. The check numbered HOF 681039 dated October 24, 1996, was for ₱5,000.00 but was altered to ₱65,000.00 and encashed with the bank. The ₱60,000.00 excess amount was said to have been misappropriated by Aliga to her personal use.
Aliga was arraigned on December 6, 1996, and pleaded not guilty.

Complaining witness Dennis T. Villareal maintained personal checking accounts with China Banking Corporation and United Coconut Planters Bank (UCPB).
Aliga, along with others, was involved in preparing checks, particularly handling the preparation and delivery of Villareal’s personal checks for signature and encashment.
Aliga had custody of Villareal's personal checks, prepared them by typing out details, and gave signed checks to a messenger for bank encashment.

Villareal’s governess inquired about the payment for horseback riding lessons for 1995; findings reveal such fees had been paid.
Elsa Doroteo, Villareal’s executive secretary, reviewed returned checks and noticed large encashments in typewritten form that Villareal had not authorized.
Villareal sought the help of the National Bureau of Investigation (NBI), which examined the checks and assisted in investigation.

Villareal signed three checks (₱1,000.00, ₱5,000.00, and ₱6,000.00) prepared by Aliga after NBI's suggestion, with Doroteo retaining photocopies and releasing originals to Aliga.
Doroteo and NBI agent checked at UCPB; a check with the amount ₱65,000.00 (altered from ₱5,000.00) was encashed.
Upon confrontation, Aliga voluntarily admitted the taking of the ₱60,000.00 excess and executed a handwritten statement surrendering the amount to Villareal.
NBI agents arrested Aliga after her admission.

Diosdado Corompido, Villareal’s messenger, corroborated Aliga’s delivery of a check for ₱65,000.00 to the bank and the encashment.
Respondent presented her defense claiming she was an accounting assistant, not responsible for Villareal’s personal accounts, and that there was no internal mechanism regulating check preparation responsibility. She also denied improper acts and alleged multiple employees used the same typewriter, complicating attribution.
Dispute arose over whether Aliga was under custodial investigation (rights advisement) during her admission; the NBI agents claimed they were silent spectators and did not interrogate her.

The RTC convicted Aliga beyond reasonable doubt and imposed an indeterminate sentence of 14 years and 8 months to 20 years reclusion temporal.
The RTC absolved Aliga of civil liability considering the return of the ₱60,000.00.

On April 27, 2004, the CA reversed the RTC judgment, acquitting Aliga.
CA ruled that Aliga’s confession was inadmissible due to lack of advisement of rights during custodial investigation.
The CA found the circumstantial evidence insufficient to overcome the presumption of innocence.

Petitioner Villareal filed a petition for review raising issues on the inadmissibility of admission and sufficiency of evidence.
Respondent argued the petition raised only factual questions, invoked double jeopardy, questioned petitioner’s standing, and upheld CA’s findings.
The Supreme Court noted procedural issues: the petition should have been filed by the Office of the Solicitor General (OSG) and invoked Rule 65 (certiorari) instead of Rule 45 (petition for review on certiorari).

Whether the Court of Appeals erred in declaring respondent’s voluntary admission of guilt inadmissible for lack of advisement of constitutional rights during custodial investigation.
Whether the Court of Appeals gravely erred in finding the prosecution’s evidence insufficient to overcome respondent’s presumption of innocence.
Whether the petition for review on certiorari filed by a private complainant was procedurally proper or whether the lack of representation by the OSG deprives the petitioner of legal standing.
Whether the appropriate remedy to assail a judgment of acquittal is a petition for certiorari under Rule 65 rather than a petition for review under Rule 45, considering the right against double jeopardy.