Title
Imperial vs. People
Case
G.R. No. 230519
Decision Date
Jun 30, 2021
Petitioner acquitted of qualified theft as prosecution failed to prove guilt beyond reasonable doubt; circumstantial evidence insufficient, presumption of innocence upheld.

Case Summary (G.R. No. 230519)

Background of the Case

The petitioner was charged with qualified theft through an Information filed on November 28, 2008, alleging that he unlawfully took a roll of Royal Cord No. 14/3 valued at Five Thousand Seven Hundred Pesos (P5,700.00) intended for maintenance work. The prosecution proceeded with the case following the petitioner’s arraignment on January 20, 2009, where he entered a plea of not guilty.

Prosecution's Evidence

The prosecution's case rested on testimonies from various employees of NTC-MPC, including the entity's Head of Operations and Purchase Department, Melody A. Lorilla, and several maintenance staff and security personnel. They testified that the petitioner had requested a purchase order for the Royal Cord, which was eventually brought into the company's warehouse and later went missing. Important logbook entries indicated that the petitioner took the cord out of the warehouse and queries were raised when it could not be found attached to the intended wash tub.

Defense's Argument

In his defense, petitioner Daniel G. Imperial contended that while he had requested the Royal Cord, it was not delivered until after he made alternative arrangements. He claimed that he had not taken the missing cord and that it was impossible for him to have done so as the vehicle assigned to transport maintenance materials was under repair. The defense also included a witness statement from his brother, Luis Imperial, supporting his account of events.

Trial Court's Ruling

On April 26, 2013, the Regional Trial Court (RTC) found the petitioner guilty of qualified theft. The court ruled that the prosecution satisfactorily proved the essential elements of the crime, including the absence of the complainant's consent and that the petitioner had abused the confidence entrusted to him. The RTC sentenced the petitioner to a lengthy prison term and required indemnification of the complainant.

Court of Appeals' Decision

The petitioner appealed the RTC’s decision. On June 14, 2016, the Court of Appeals (CA) affirmed the RTC's ruling, emphasizing that the inconsistencies pointed out by the petitioner did not undermine the prosecution's claims. The CA also modified the sentence, refining the specifics of the imposed penalty.

Grounds for Review

In seeking the Supreme Court's review, the petitioner argued that the CA erred in affirming his conviction, claiming that the prosecution did not meet its burden of proof and that there was grave abuse of discretion in how the testimonies were evaluated. The respondent maintained that the petition sought to rehear factual matters inappropriate for a review.

Supreme Court's Findings

The Supreme Court established that it primarily reviews questions of law rather than fact, though exceptions permitting review exist under certain circumstances. The Court viewed that the CA erred, given that it did not sufficiently substantiate the factual matrix needed for a conviction of qualified theft. It noted that the prosecution primarily relied on circumstantial evidence, which lacked the required weight to sustain a conviction beyond reasonable doubt.

Analysis of the Evidence and Judgment

The Court found that the prosecution failed to adequately prove that t

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