Case Summary (G.R. No. 233033)
Charges and Background
The Igdalinos, along with their son, were charged with qualified theft under Article 310 of the Revised Penal Code for allegedly harvesting 2,500 pieces of coconuts valued at Php 4,000. The prosecution asserted that the Igdalinos committed this act without the consent of the property owner, Avertino Jaboli. During the proceedings, their son, Romeo Igdalino Jr., was acquitted due to being underage at the time of the incident.
Evidence Presented
The prosecution’s case established that the land where the coconuts were harvested (Lot No. 1609) was registered under Francisco Jaboli, Avertino's father. After Francisco’s death, his children, including Avertino, inherited the property. Felicisimo Bacarra, Avertino's caretaker since 1985, testified that he witnessed the Igdalinos picking the nuts on the morning of June 29, 2000. Conversely, the defense presented testimonies claiming that Rosita inherited the land from her father, Narciso Gabejan, and that the Igdalinos had cultivated coconuts there since their marriage in 1981.
The Ruling of the Regional Trial Court
The Regional Trial Court (RTC) found the Igdalinos guilty of qualified theft, sentencing them to imprisonment and ordering them to pay damages to Avertino. The court's decision rested profoundly on the interpretation that the Igdalinos lacked a legally justified belief in owning the land, which negated the defense of an honest claim of right.
Appeal and Court of Appeals Decision
On appeal, the Court of Appeals (CA) affirmed the RTC's ruling, supporting the rationale that the Igdalinos' belief in their ownership was not sincere or reasonable. The CA’s decision highlighted a prior adjudication that established the property’s title was granted to Avertino, thereby influencing the perception of intent to gain or an honest belief in ownership.
Supreme Court Analysis
Upon review, the Supreme Court found substantial merit in the Igdalinos' appeal, reversing the decisions of the lower courts. The Court emphasized that the prosecution failed to demonstrate beyond a reasonable doubt the essential elements of qualified theft, particularly regarding the intent to gain unlawfully and without the consent of the property owner. The
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Case Information
- Citation: 836 Phil. 1178
- Division: First Division
- G.R. No.: 233033
- Date: July 23, 2018
- Petitioners: Romeo Igdalino and Rosita Igdalino
- Respondent: People of the Philippines
- Decision By: Tijam, J.
Background and Antecedents
- The case originated from a Petition for Review on Certiorari challenging the Decision dated February 23, 2017, and the Resolution dated June 29, 2017, of the Court of Appeals in CA-G.R. CEB CR. No. 02642.
- The Court of Appeals had affirmed the Decision dated December 2, 2014, by the Regional Trial Court (RTC), Branch 28 of Catbalogan City.
- The Igdalinos were found guilty of qualified theft for harvesting 2,500 pieces of coconut fruits valued at Php4,000.00 from the plantation of Avertino Jaboli without consent.
Charge Details
- The information charged the Igdalinos with qualified theft under Article 310 of the Revised Penal Code, specifically for taking property valued at P4,000.00 from Avertino Jaboli's coconut plantation.
- During the arraignment, the Igdalinos pleaded not guilty; however, their son Romeo Igdalino, Jr. was dismissed from the case due to his age.
Prosecution Evidence
- The coconut plantation in question was registered under the name of Francisco Jaboli, Avertino's deceased father.
- Felicisimo Bacarra, the caretaker of the plantation since 1985, testified that he saw the Igdalinos harvesting coconuts.
- Avertino's sister, Lilia Dabuet, corroborated the ownership by