Case Digest (G.R. No. 205180) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ryan Viray v. People of the Philippines (G.R. No. 205180, November 11, 2013), petitioner Ryan Viray was charged by information before the Regional Trial Court (RTC) of Cavite City, Branch 16, with qualified theft for allegedly stealing jewelry, a Gameboy, a CD player, a Nokia cellphone and a jacket valued at ₱297,800.00 from his employer, Zenaida S. Vedua, on October 19, 2006, in Cavite City. Viray was employed as a dog caretaker and worked from early morning to late afternoon but was never permitted inside Vedua’s house. On the day of the incident, Vedua locked her doors before departing for Batangas, and later discovered that the doors had been forced open and her valuables missing. A plastic bag containing Viray’s clothes was found inside the house, and witnesses placed Viray at the crime scene carrying a large sack. Viray pleaded alibi, claiming illness and non-attendance at work, which was supported by family testimony. The RTC convicted him of robbery, finding that forc Case Digest (G.R. No. 205180) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural posture
- Petitioner Ryan Viray was charged by Information in RTC Cavite City, Branch 16, with qualified theft of jewelry, electronics, and clothing valued at ₱297,800.00. He pleaded not guilty.
- After trial, the RTC convicted him of robbery (finding force upon things) and sentenced him to 4 years, 2 months, 1 day to 8 years prision mayor.
- Appellate proceedings
- On appeal, the Court of Appeals (CA) held that robbery could not be charged (force was not alleged) but convicted Viray of qualified theft (grave abuse of confidence) and imposed 4 months, 1 day arresto mayor to 2 years, 4 months, 1 day prision correccional with restitution.
- The CA denied Viray’s motion for reconsideration.
- Facts of the incident
- Employment and access
- Viray was a dog caretaker for private complainant Zenaida Vedua, working daily from 6:00 a.m. to 5:30 p.m. with no permission to enter Vedua’s house interior.
- On October 19, 2006, Vedua left home at 7:00 a.m., locking all doors, and returned at 7:00 p.m. to discover missing items and broken doors.
- Missing property and circumstantial evidence
- Vedua’s missing items included jewelry (₱275,000), a Gameboy, CD player, Nokia phone, and jacket, totalling ₱297,800.00.
- A plastic bag with Viray’s t-shirt and shorts was found inside the house.
- Witness Nimfa Sarad saw Viray at 6:00 a.m. and leaving with a sack around 11:00 a.m.; Leon Young saw him descending Vedua’s stairs with a companion at about 10:00–11:00 a.m.; laundrywoman Beverly Calagos left him alone at 8:30 a.m.; Viray never returned to work.
- Defense of alibi and denial
- Viray claimed he missed work on October 19 due to flu, his mother notified Vedua at 5:30 a.m., and his sister and aunt corroborated his illness and absence.
Issues:
- Classification of the crime
- Whether the taking constituted robbery, qualified theft, or simple theft.
- Sufficiency of allegation and proof
- Whether the Information properly alleged force upon things to sustain a robbery charge.
- Whether grave abuse of confidence existed to elevate theft to qualified theft.
- Whether the prosecution proved the value of the stolen property for penalty determination.
- Relief awarded
- Whether restitution order should stand absent proof of pecuniary loss.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)