Title
Zabala vs. People
Case
G.R. No. 210760
Decision Date
Jan 26, 2015
Kyle Zabala acquitted of theft as Supreme Court found insufficient evidence; circumstantial proof failed to exclude others' involvement, upholding presumption of innocence.

Case Digest (G.R. No. 210760)
Expanded Legal Reasoning Model

Facts:

  • Procedural Background
    • An Information was filed in the Regional Trial Court (RTC), Branch 22, Malolos City, charging petitioner Kyle Anthony Zabala with theft under Articles 308 and 309 of the Revised Penal Code.
    • The Information charged that on or about June 18, 2007, in San Jose del Monte City, Bulacan, Zabala with intent to gain unlawfully took an envelope containing cash amounting to ₱68,000 from Randolph V. Alas, the owner, without his knowledge or consent.
    • Upon arraignment, petitioner pleaded not guilty.
  • Trial Proceedings and Evidentiary Presentation
    • The trial on the merits involved testimonies from:
      • Complainant Randolph V. Alas, who detailed his routine, his relationship with Zabala as a neighbor and kumpare, and the circumstances leading to the discovery of the missing cash.
      • Marlyn PiAon, alleged former girlfriend of Zabala, who testified that she witnessed Zabala scaling the fence and entering Alas’s house and observed a bulge in his pocket on his return.
    • The defense presented:
      • The testimony of petitioner Zabala, asserting that on the night preceding the alleged incident, he was driving his jeepney in the company of his friend Muriel John Ganas.
      • Ganas corroborated Zabala’s version by stating that they were together and that Zabala did not visit Alas’s residence.
  • Narrative of the Incident
    • According to the prosecution’s version:
      • Complainant Alas left for work at around 4:00 a.m. on June 18, 2007, and returned around 11:00 p.m. only to find his ₱68,000 missing.
      • Testimony by PiAon indicated that Zabala was seen climbing the fence and entering the complainant’s house early that morning.
      • After exiting the house, Zabala was noted to have a noticeable bulge in his pocket.
      • Subsequently, Zabala and PiAon were recorded shopping in Greenhills, where he purchased two mobile phones, suggesting possible use of the alleged stolen cash.
    • According to the defense’s version:
      • Zabala maintained that he was with his friend Ganas from early June 17 until their parting on the morning of June 18.
      • He claimed that he never visited the complainant’s house and that his relationship with PiAon was merely that of an acquaintance.
      • Ganas’s testimony served to reinforce that Zabala was continuously in transit with him during the crucial time period.
  • Decision of the Lower Courts
    • RTC Decision (July 7, 2011):
      • The RTC found petitioner guilty beyond reasonable doubt of the crime of theft.
      • Zabala was sentenced to suffer imprisonment under prision correccional (minimum 6 years, maximum 8 years) and ordered to indemnify Alas with ₱68,000.
    • Court of Appeals (CA) Decision (July 15, 2013) and Resolution (January 8, 2014):
      • The CA affirmed the RTC’s judgment with modification by imposing a slightly altered penalty range (minimum of 6 years to a maximum of 12 years, 8 months, and 8 days) while reiterating the finding of guilt.
      • The CA found that the circumstantial evidence, when taken together, was sufficient to establish the chain of circumstances leading to a conviction.
  • Appellate and Supreme Court Review
    • Petitioner filed a Petition for Review on Certiorari under Rule 45, challenging:
      • The weight and credence given to the prosecution witnesses’ testimonies.
      • The sufficiency of evidence presented to support the conviction.
      • The reliance on circumstantial evidence as the basis for convicting him.
    • The People, as respondent, maintained that the evidence was sufficient and that the CA correctly applied the doctrine of circumstantial evidence.

Issues:

  • Whether the Court of Appeals erred in giving full weight and credence to the testimonies of the prosecution witnesses.
  • Whether the CA erred in affirming the RTC’s decision despite the contention that the evidence on record failed to support a conviction beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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