Title
Atienza vs. People
Case
G.R. No. 188694
Decision Date
Feb 12, 2014
CA employees accused of theft and falsification of court records acquitted due to insufficient circumstantial evidence and jurisdictional defects.

Case Summary (G.R. No. 188694)

Key Dates and Procedural Posture

Material factual events occurred in March–May 1995 (search and disappearance of CA Original Decisions volume, attempts to insert documents, and the return of Volume 266). Administrative and criminal fact-finding by CA officers and the NBI followed. The Departmental/Ombudsman preliminary investigation produced a finding of probable cause for Robbery (Article 299(a)(1), RPC) and Falsification of Public Document (Article 172(1) in relation to Article 171(6), RPC) and Informations were filed as Criminal Case Nos. 01-197425 and 01-197426. The Regional Trial Court (RTC), Branch 21, Manila, convicted petitioners; the Court of Appeals affirmed; the Supreme Court granted review and ruled on the appeal.

Applicable Law and Constitutional Basis

The 1987 Philippine Constitution served as the constitutional framework. Penal provisions implicated included Article 299(a)(1) (Robbery in an inhabited house or public building), Article 172(1) (Falsification by a private individual and use of falsified documents) in relation to Article 171(6) (alteration or intercalation in a genuine document by a public officer, employee or notary). Other statutes referenced in the record include Section 3(a) of RA 3019 (Anti-Graft and Corrupt Practices Act), Section 8 of RA 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees), Batas Pambansa Blg. 129 Section 32(2) (jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts), and RA 7691 (amending BP 129).

Factual Summary — Events Leading to the Dispute

On March 20, 1995, Castro invited Atibula to a birthday party for Atienza; Atibula was introduced to a man identified as Dario and asked to assist Dario in searching for the CA decision in Mateo Fernando v. Heirs of D. Tuason, Inc., found in Volume 260 of the CA Original Decisions. Dario scanned Volume 260 (and later Volumes 265 and 267) comparing pages to discolored papers he held and placed check marks on those papers. On March 24, 1995, Dario allegedly requested Atibula to insert a Decision dated September 26, 1968 into a volume, which Atibula refused. On April 21, 1995, Atienza allegedly offered Atibula P50,000 for Volume 260; Atibula refused and hid Volumes 260, 265 and 267. On May 9, 1995, Atibula discovered that Volume 266 (covering Jan. 28–Feb. 12, 1969) was missing and reported the loss. On May 18, 1995, Nelson de Castro delivered a bag containing Volume 266 to Atibula and claimed Castro instructed him to do so.

Discovery of Alterations and Forensic Findings

Upon examination, Volume 266 was found to contain two newly inserted documents not listed in earlier compilations: a Resolution dated February 11, 1969 (purporting to recall and set aside an Entry of Judgment) and a Decision dated April 16, 1970 (purporting to amend the original September 26, 1968 decision), both attributed to Associate Justice Juan P. Enriquez with concurrences noted. NBI laboratory analysis found that Volume 266 had been altered and that the questioned signatures on the inserted documents were not written by the same hand as the standard signatures of the justices, leading to the conclusion that those signatures were forgeries. An ocular inspection revealed an opening in the concrete wall near an air-conditioning unit, with signs that the unit had been removed and the supporting angle bar corroded, supporting the inference of entry through an opening not intended for ingress or egress.

Procedural History and Trial Dispositions

The NBI and the Office of the Ombudsman’s Fact-Finding and Intelligence Bureau filed criminal complaints, and after preliminary investigation the charges under RA 3019 and RA 6713 were dismissed for insufficiency of evidence, but probable cause was found for Robbery (Art. 299(a)(1), RPC) and Falsification of Public Document (Art. 172(1) in relation to Art. 171(6), RPC). The RTC, after trial, convicted petitioners for both offenses and imposed indeterminate sentences for Robbery and prision correccional plus a fine for Falsification. The Court of Appeals affirmed the conviction on appeal; a motion for reconsideration was denied. Petitioners then filed the present petition for review on certiorari.

Issue Presented to the Supreme Court

Whether the circumstantial evidence in the record established beyond reasonable doubt the elements of Robbery under Article 299(a)(1) of the Revised Penal Code and Falsification of Public Document under Article 172(1) in relation to Article 171(6) of the Revised Penal Code, and whether a conspiracy between petitioners could be inferred from the proved circumstances.

Legal Standard for Circumstantial Evidence Applied by the Court

The Court articulated the well-established test for conviction based on circumstantial evidence: (a) there must be more than one circumstance; (b) the facts from which the inferences are derived must be proven; and (c) the combination of all circumstances must produce moral certainty of guilt beyond reasonable doubt. Crucially, circumstantial evidence must form an unbroken chain that leads to a fair and reasonable conclusion pointing to the accused, to the exclusion of others. Each circumstance must be consistent with the accused’s guilt and inconsistent with his innocence.

Court’s General Conclusion on Sufficiency of Circumstances

Applying the circumstantial-evidence test to the record, the Court found that the prosecution failed to establish an unbroken chain of convincing circumstances linking petitioners to the commission of Robbery and Falsification beyond reasonable doubt. The Court determined that the circumstantial proof was not sufficient to exclude other reasonable explanations or to single out petitioners as the perpetrators to the exclusion of others.

Analysis: Evidence Against Castro

The prosecution’s claim that Castro was in possession of and caused the return of Volume 266 depended solely on the sinumpaang salaysay of Nelson de Castro, who was not produced at trial. The Court reiterated that affidavits, though public documents if notarized, are hearsay unless the affiants testify in court and are subject to cross-examination. Because Nelson was not examined in court, his statement concerning Castro’s direction to deliver the volume remained hearsay and inadmissible to establish the fact asserted. In the absence of any other competent evidence tying Castro to the taking or falsification of the volume, the Court concluded that there was no sufficient circumstantial evidence to prove Castro’s guilt.

Analysis: Evidence Against Atienza

Atibula identified Atienza as having attempted to bribe him to remove Volume 260; however, the falsification occurred in Volume 266. The Court emphasized that this discrepancy undermines the probative weight of the bribery episode as direct proof of the charged offenses. The attempted bribery, properly viewed, establishes only motive or interest and not dispositive proof of participation in the actual falsification or unauthorized removal of Volume 266. Additional circumstances relied upon by the prose

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