Title
Medina vs. People
Case
G.R. No. 182648
Decision Date
Jun 17, 2015
Mechanic Herman Medina convicted of simple theft for unlawfully removing parts from a client’s jeep during repairs; SC upheld conviction, citing unsubstantiated defense and sufficient circumstantial evidence.

Case Summary (G.R. No. 182648)

Information and Charge

Medina was charged by Information with simple theft (Article 308, in relation to Article 309, Par. 1, of the Revised Penal Code) for taking without consent and with intent to gain certain jeep parts — alternator (₱5,000), starter (₱5,000), battery (₱2,500), and two tires with mags (₱10,000) — totaling ₱22,500.

Trial Proceedings and Evidence

At arraignment Medina pleaded not guilty. No settlement, stipulation, or admission was made during pre-trial. The prosecution presented Danilo Beltran and Henry Lim, whose testimonies established that the jeep was complete when delivered and that the specified parts were missing when it was recovered. Medina testified in his defense and called Angelina Tumamao. Medina admitted removing the parts but asserted they were lawfully transferred to Lim’s pick-up; he and defense witnesses identified an acknowledgment receipt (dated July 25, 2002) that allegedly documented the transfer, though the receipt was not formally offered into evidence during trial.

Trial Court Decision

The Regional Trial Court found Medina guilty beyond reasonable doubt of simple theft. The court applied the Indeterminate Sentence Law, sentencing him to imprisonment of three years, six months and twenty-one days (prision correccional) as minimum, to eight years, eight months and one day (prision mayor) as maximum, and ordered indemnification of ₱22,500. The trial court discredited the defense explanation and found the prosecution witnesses credible.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC. The CA characterized Medina’s explanation that he had installed the jeep parts on Lim’s pick-up as “so lame and flimsy.” It agreed that Medina failed to prove (a) Lim owned the pick-up, (b) the missing parts in fact corresponded to those placed in the pick-up, (c) Lim consented to the transfer, and (d) there was corroboration of Mendoza’s alleged witnessing of the transfer. The CA also noted Medina’s failure to formally offer documentary proof (the acknowledgment receipt) into evidence.

Issues Raised in the Petition to the Supreme Court

Medina’s petition under Rule 45 contended, inter alia:

  1. Conviction was improper because prosecution presented only circumstantial evidence and specifically relied on a single circumstance (Beltran’s testimony), invoking Section 4, Rule 133.
  2. The prosecution relied on the weakness of the defense rather than affirmative proof.
  3. There was no furtive taking or unlawful asportation because the taking, if any, was with the owner’s knowledge or acquiescence (citing Abundo).
  4. The trial court and CA erred in not considering the acknowledgment receipt (Exhibit “2” / Exhibit “C”) despite exceptions allowing reception of evidence not formally offered.

Legal Elements of Simple Theft as Applied

The Court reiterated the elements of theft under Article 308: (1) taking of personal property, (2) property belongs to another, (3) intent to gain, (4) lack of owner’s consent, and (5) no force/violence. Intent to gain is generally presumed from unlawful and furtive taking. The term “taking” under the theft provision does not strictly require asportation; appropriation suffices when the owner is deprived of possession.

Admission of Taking and Burden Shift

Medina admitted taking the jeep parts. The Court applied the principle that such admission shifts the burden to the accused to prove the lawfulness of the taking. Medina failed to discharge that burden: he did not satisfactorily prove ownership of the pick-up by Lim, identity and identity of parts transferred, owner’s consent, or corroboration by Mendoza. The absence of documentary corroboration and failure to present Mendoza as a witness were highlighted.

Documentary Evidence and Mato Exception

The defense identified an acknowledgment receipt dated July 25, 2002 (marked in trial as Exhibit “C” by the prosecution’s prayer), but it was not formally offered and incorporated into the records. The Court discussed the Mato v. CA exception permitting admission of evidence not formally offered if (1) the item was duly identified by recorded testimony and (2) the item was incorporated in the records. Although the receipt was attached as Annex “3” to Medina’s appellant’s brief, the Court found it had not been incorporated in the trial record; thus, it could not be treated as formal evidence. Even if admitted, the receipt would not have exculpated Medina because the signatories admitted they did not actually see him transfer the parts.

Credibility and Weight of Denials

The Court emphasized established jurisprudential caution toward uncorroborated denials, noting that denial is inherently weak and unreliable and cannot prevail over positive and categorical testimonies. The trial court’s and CA’s credibility determinations — favoring the prosecution witnesses (Beltran and Lim) over Medina’s self-serving explanations — were held to be reasonable and not subject to reversal in the absence of compelling reasons.

Abundo and Consent Argument

Medina relied on Abundo v. Sandiganbayan to argue absence of felonious taking due to owner’s consent. The Court distinguished Abundo: there the owner (the Government) granted written permission and a receipt for the chassis taken. In contrast, no evidence in the present case showed that Lim consented to the transfer of parts or that possession was voluntarily relinquished; therefore Abundo’s principle did not apply.

Assessment of Evidence and Stan

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