Title
Estrella y Gili vs. People
Case
G.R. No. 212942
Decision Date
Jun 17, 2020
Petitioner convicted of fencing stolen Skydrol hydraulic fluid from PAL, failing to prove legitimate ownership; SC affirmed conviction, rejecting defenses of denial and frame-up.
stolen hydraulic fluid
factual findings
malum prohibitum offenses
A

Case Summary (G.R. No. 212942)

Charge and Information

Petitioner was charged by Information with violation of Section 2, Presidential Decree No. 1612 (Anti‑Fencing Law) for allegedly acquiring, possessing, selling and disposing of three five‑gallon pails of Skydrol LD‑4 hydraulic fluid valued at approximately ₱27,000, knowing or having reason to know that the items were stolen or derived from theft, to the prejudice of PAL.

Procedural History

Petitioner pleaded not guilty, was tried at RTC Branch 119, convicted on February 15, 2010; conviction affirmed by the Court of Appeals on November 20, 2013; CA denied reconsideration on June 3, 2014. Petitioner filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court. The Supreme Court, applying the 1987 Philippine Constitution as the governing charter for cases decided after 1990, denied the petition and affirmed the conviction with modification of the penalty.

Facts Found by Trial and Appellate Courts

PAL observed unusually high consumption of Skydrol despite downsizing, prompting investigation. PAL provided the police with a sample and manufacturer lot number. PNP‑CIDG surveillance on June 19 and 22, 1999, identified petitioner delivering three pails of Skydrol to Air Philippines; petitioner was photographed and later apprehended while about to deliver the three pails. Petitioner failed to produce documents proving lawful ownership or source, claiming an unproduced supplier named “Jupel” and asserting purchase from International Business Aviation, Inc. (closed). PAL’s Yao identified the pails as part of PAL’s stock, and Solutia certified that five‑gallon Skydrol pails with the lot number at issue were sold and imported only to PAL and that Solutia had not authorized Aerojam as a reseller.

Evidence Presented by the Prosecution

Key evidence included PO3 Bolido’s detailed surveillance and apprehension testimony (identifying petitioner handling the pails, inability to produce documents, transport to Camp Crame), Yao’s testimony identifying the pails and explaining PAL’s exclusive importation/use of five‑gallon Skydrol, photographs of petitioner and the jeep, manufacturer lot numbers on the pails, Solutia’s certification/Certificate of Analysis, Bill of Lading, and invoices showing shipment and sale to PAL.

Defense Evidence and Theory

Petitioner testified that he regularly sold aircraft parts and chemicals, transacted with multiple airlines, obtained Skydrol from IBAI (now closed), and that he was framed. He asserted other airlines used Skydrol and that lot numbers are not uniquely assigned to a particular airline. Alvin Ygona testified for the defense about distribution practices and lot number commonality.

Issues Raised on Appeal to the Supreme Court

Petitioner chiefly argued (1) PAL concocted documentary evidence and (2) the prosecution failed to prove guilt beyond reasonable doubt. Respondent argued the evidence proved PD 1612 violation, petitioner’s defenses were baseless, and that only questions of law are reviewable under Rule 45.

Procedural Law: Scope of Rule 45 Review

The Court reiterated that Rule 45 petitions should present questions of law; the Supreme Court is generally not a trier of facts. Factual findings of the trial court, especially when affirmed by the appellate court, are accorded great weight and not lightly disturbed. Exceptions allowing factual reevaluation were considered inapplicable here.

Elements of the Offense (PD 1612) and Legal Standards Applied

The Court set out the essential elements of Fencing under Section 2, PD 1612: (1) a crime of robbery or theft has been committed; (2) the accused, not a principal/accomplice, deals in an article or thing of value derived from the proceeds of theft; (3) the accused knows or should have known the item derived from theft; and (4) intent to gain. The Court also emphasized Section 5’s presumption that mere possession of goods that were the subject of robbery or theft is prima facie evidence of fencing.

Factual Findings Applied to Elements — Theft and Ownership

The Court accepted the RTC/CA finding that theft from PAL had occurred, relying on PAL’s documented inventory anomalies, Solutia’s certification, Bills of Lading, invoices, and Certificate of Analysis establishing shipment and sale of the lot to PAL. These records, corroborated by witness testimony, supported the conclusion that the three pails found with petitioner belonged to PAL.

Factual Findings Applied to Elements — Possession and Knowledge

The Court found petitioner was caught in possession and in the act of delivering the pails to Air Philippines based on PO3 Bolido’s surveillance testimony and corroboration by photographs and Yao’s identification. Petitioner’s inability to produce the alleged source (“Jupel”) or supporting documents and his uncorroborated account constituted sufficient grounds to conclude he knew or should have known the goods were derived from theft.

Factual Findings Applied to Elements — Intent to Gain and Presumption of Fencing

Given possession, identification of ownership by PAL, and failure to rebut the presumption, the Court upheld that intent to gain was established. The Court reiterated that PD 1612 creates a prima facie presumption of fencing from possession of stolen goods; as a malum prohibitum offense, proof of the prohibited act is dispositive and petitioner bore the burden to overcome the statutory presumption, which he failed to do.

Assessment of Defense Claims (Denial and Frame‑up)

The Court found petitioner’s denial and frame‑up defense uncorroborated and unsupported by credible evidence. The absence of corroborative witnesses (e.g., petitioner’s wife) or complaints alleging frame‑up, and petitioner’s failure to produce Jupel or documents, undermined his defense. The Court observed that unsubstantiated denial cannot prevail against positive and consistent prosecution testimony.

Rule 45 Limitation and Deference to Lower Courts

The Supreme Court emphasized that petitioner’s arguments primarily raised factual disputes and credibility questions—matters within the trial court’s province. No

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