Case Summary (G.R. No. 228745)
Relevant Dates
The initial Information was filed on May 20, 2011, with the MTCC delivering its Judgment shortly thereafter. The RTC's Decision was promulgated on March 4, 2014, and the CA's Decision followed on July 20, 2016, with a subsequent Resolution on October 17, 2016. The case is ultimately reviewed under the 1987 Philippine Constitution due to the date of the decision being in 2020.
Legal Basis
The crime charged is Theft, defined and penalized under Article 308 in relation to Article 309 of the Revised Penal Code (RPC). The essential elements of theft include the unlawful taking of personal property belonging to another, with intent to gain and without the owner's consent, accomplished without violence or intimidation.
Case Background
On January 7, 2011, Carlu Alfonso A. Realiza was accused of stealing rubber boots, an iron pot, and a frying pan valued at P1,600 from complainant Elfa L. Boganotan's residence. Witnesses, including Elfa and her son Kim, provided testimonies supporting the allegation of theft. Elfa stated she was informed about the theft by Kim, who witnessed Realiza entering their house.
Defense and Counterarguments
Realiza denied the allegations, claiming he was elsewhere at the time of the purported theft. He argued that the accusations arose from conflicts with his uncle George Realiza and that the allegations were fabricated. He presented witness accounts corroborating his alibi that he was not present at the scene of the crime.
Rulings at MTCC and RTC
The MTCC found Realiza guilty of Theft, sentencing him to imprisonment and ordering restitution of the stolen items' value to Elfa. This decision was appealed to the RTC, which affirmed the MTCC's ruling, finding no reversible error.
Court of Appeals Decision
The CA upheld the RTC's findings, affirming Realiza's guilt. The CA emphasized that the ocular evidence and the timely accounts from the prosecution witnesses were credible and compelling, dismissing the appellant's claims of fabricated testimony.
Supreme Court's Analysis of the Petition
The Supreme Court reiterated that the trial court's factual findings and assessments of witness credibility are generally accorded great respect. Realiza's defense, particularly his alibi, was deemed weak since the prosecution's evidence established the timeframe in which the theft occurred, countering his claims.
Conclusion on Guil
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Overview of the Case
- This case involves a Petition for Review on Certiorari filed by Carlu Alfonso A. Realiza against the People of the Philippines, seeking the reversal of the Court of Appeals' (CA) decisions which affirmed his conviction for theft.
- The case was filed under Rule 45 of the Rules of Court and originates from the Regional Trial Court (RTC), which upheld the Municipal Trial Court in Cities (MTCC) ruling.
- The relevant decisions were issued on July 20, 2016, and October 17, 2016, by the CA, confirming the lower courts' findings.
Facts of the Case
- Carlu Alfonso A. Realiza was charged with theft in an Information dated May 20, 2011, for stealing items belonging to Elfa L. Boganotan on January 7, 2011.
- The items stolen included rubber boots, an iron pot, and a frying pan, valued at P1,600.00.
- Testimonies from the complainant, Elfa Boganotan, and her son, Kim Boganotan, described the incident where Kim witnessed petitioner taking the items from their house.
- Petitioner denied the accusations, providing an alibi that he was not present during the incident as he was in Labrador, Polanco at the time.
- Several witnesses corroborated his claim, including Salvador Eba, Jr., who saw petitioner on a motorcycle and Rosemarie Hangcan, who