Case Summary (G.R. No. 146584)
Factual Background
The case revolves around Ernesto Francisco, who was charged with violating the Anti-Fencing Law by purchasing jewelry that was allegedly stolen. The indictment against him was filed on June 23, 1993, relating to several pieces of jewelry valued at P 655,000. The complainant, Jovita Rodriguez, discovered that her jewelry, which was locked in a cabinet, was missing shortly after hiring Pacita Linghon as a domestic helper, who subsequently purportedly sold the stolen items to Francisco. The prosecution claims that Francisco knowingly acquired these stolen goods.
Proceedings and Findings
The Regional Trial Court of Malolos, Bulacan, found Francisco guilty, sentencing him to a prison term ranging between ten years and one day to twenty years, along with financial restitution for the stolen jewelry. The trial emphasized testimonies from the complainant and various witnesses, including police officers and Pacita, who was implicated in the theft and later testified against Francisco.
Issues on Appeal
Francisco appealed, arguing that the testimonies against him were hearsay and lacked the requisite credibility to sustain a conviction. He highlighted inconsistencies in witness testimonies and claimed that the prosecution did not establish that he was aware the jewelry was stolen.
The Court of Appeals' Ruling
The Court of Appeals upheld the Regional Trial Court's decision, indicating that there was sufficient evidence to infer that Francisco should have known the jewelry was stolen based on the price disparity when it was sold compared to its alleged market value.
Supreme Court's Review
The Supreme Court found merit in Francisco's petition, holding that essential elements of the crime under P.D. No. 1612 were not adequately proven beyond a reasonable doubt. Specifically, it noted that ownership and authentication of the stolen property were crucial, and the prosecution's reliance on evidence from prior cases involving Pacita did not sufficiently establish Francisco's guilt, as he was not a party to those proceedings.
Evaluation of Evidence
The Supreme Court pointed out that without establishing credible knowledge of the jewel
...continue readingCase Syllabus (G.R. No. 146584)
Case Background
- This case involves an appeal by Ernesto Francisco y Spenocilla against a decision by the Court of Appeals affirming his conviction for violating Presidential Decree No. 1612, the Anti-Fencing Law.
- The Regional Trial Court of Malolos, Bulacan, initially found Francisco guilty and sentenced him to a term of imprisonment of ten (10) years and one (1) day to twenty (20) years, along with the obligation to pay the value of the stolen jewelry.
Indictment Details
- The indictment was filed on June 23, 1993, charging Francisco with buying, receiving, possessing, and acquiring stolen jewelry valued at P 655,000.00 which belonged to Jovita Rodriguez y Cruz.
- The pieces of jewelry included a pair of earrings, a white gold bracelet, and two diamond rings, all stolen by Pacita Linghon, who was previously employed by the victim.
Case for the Prosecution
- Jovita Rodriguez: Victim of the theft, owned the jewelry, and testified about the circumstances of the theft and her suspicion towards Pacita.
- Pacita Linghon: Former household helper who contacted her brother Macario to sell the stolen jewelry after leaving her employment with Jovita.
- Macario Linghon: Sold the jewelry to Francisco, initially for P 25,000, then later for P 18,000. He testified about the transactions and identified Francisco as the buyer.
- The prosecution presented evidence including sworn statements and testimonies to establish that Pacita stole the jewelry and sold it to Francisco.
Case for the Petitioner
- Ernesto Francisco: Claimed ignorance of the