G.R. No. 80762 - People vs. Gonzales

Case Summary (G.R. No. 80762)

Facts and Chronology

An Information was filed against Aliga on October 31, 1996, accusing her of willfully and unlawfully falsifying a company check and converting ₱60,000.00 for her own use. Aliga pleaded not guilty during arraignment. The Regional Trial Court (RTC) conducted trial proceedings, where both parties presented witnesses and documentary evidence. Key prosecution witnesses included Villareal's executive secretary Elsa Doroteo, messenger Diosdado Corompido, chief accountant Yolanda Martirez, and NBI agent John Leonard David.

Detailed Factual Background

Villareal maintained company and personal checking accounts at China Banking Corporation and United Coconut Planters Bank (UCPB). Aliga was responsible for handling Villareal’s personal checks, including preparing and submitting them for signature and delivery to the messenger for encashment. An irregularity arose when the company's executive secretary discovered a check for ₱5,000.00 had been altered to ₱65,000.00. Upon verification, Villareal observed unauthorized large encashments on his returned checks.

Investigation and Arrest

Acting on legal advice, Villareal sought assistance from the National Bureau of Investigation (NBI). NBI agents investigated and observed three unsigned petty cash checks prepared by Aliga which Villareal signed as suggested by agents. They monitored encashment at UCPB, where a check altered to ₱65,000.00 was cashed, differing from the original amount of ₱5,000.00. Aliga was confronted, voluntarily surrendered ₱60,000.00, and was subsequently arrested by NBI agents.

Aliga’s Defense and Counter-Claims

Aliga denied responsibility for the alteration, stating she was an accounting assistant and not the custodian of Villareal’s personal checking accounts. She claimed that other employees prepared checks, that no single individual had exclusive check-preparation responsibility, and that the office lacked control or regulatory mechanisms identifying individual responsibility for the checks. She also asserted that the NBI agents did not inform her of her constitutional rights upon arrest.

RTC's Findings and Judgment

The RTC found the evidence against Aliga sufficient beyond reasonable doubt to prove that she altered the check and committed qualified theft. It noted her handwritten admission returning the ₱60,000.00 as corroborative evidence. Consequently, the RTC convicted her, imposing an indeterminate sentence of 14 years and 8 months to 20 years of reclusion temporal but absolved her of civil liability due to the return of the money.

Court of Appeals (CA) Ruling

On appeal, the CA reversed the RTC’s conviction, acquitting Aliga. It held that her confession was inadmissible because it was obtained during a custodial investigation without informing her of her rights to remain silent and have counsel, violating procedural safeguards under the Constitution. The CA further held that the circumstantial evidence presented was insufficient to overcome the presumption of innocence.

Issues Raised in the Petition for Review

Whether the CA erred in declaring Aliga’s voluntary admission inadmissible on speculative grounds of custodial investigation despite an absence of coercion or duress.
Whether the CA improperly set aside the RTC’s findings by requiring direct evidence beyond reasonable doubt and incorrectly faulting the prosecution’s evidence.
The propriety of the CA’s reliance on Aliga’s denials over RTC’s credibility assessments.

Respondent’s Arguments in Opposition

Aliga contended:

The petition raises only factual issues and should be dismissed.
The petition violates the rule against double jeopardy.
Petitioner lacks legal standing to file the petition as the complainant, not the State.
The CA’s decision aligns with the facts, law, and jurisprudence.

Procedural Deficiency: Standing and Mode of Appeal

The Supreme Court emphasized that in criminal cases, only the Office of the Solicitor General (OSG) may represent the State in appealing judgments acquitting an accused. Private complainants’ participation is limited to the civil aspect of the case. Thus, petitioner’s filing of the petition for review on certiorari without the OSG’s representation rendered the petition procedurally defective due to lack of legal standing.

Mode of Appeal: Rule 45 vs. Rule 65

The Court stressed that a judgment of acquittal is final and not appealable via petition for review under Rule 45 of the Rules of Court as this would violate the constitutional protection against double jeopardy. The proper recourse to assail an acquittal is through a petition for certiorari under Rule 65 based on grave abuse of discretion or lack of jurisdiction. Petitioner’s failure to comply with this procedural requisite constituted another ground for dismissal.

Double Jeopardy and Finality of Acquittal

The Court reaffirmed the constitutional protection against double jeopardy, which prohibits repeated prosecution for the same offense after acquittal. The finality of the acquittal protects the accused’s right to repose and shields against government harassment. This principle precludes the State (except via Rule 65 certiorari) fr

Case Syllabus (G.R. No. 80762)

Facts of the Case

On October 31, 1996, an Information was filed against Consuelo C. Aliga for Qualified Theft through Falsification of Commercial Document, alleging unauthorized alteration and encashment of a check from Dentrade Inc., represented by Dennis T. Villareal.
The check in question was originally issued in the amount of ₱5,000.00 but was allegedly altered to ₱65,000.00 by adding digits, and the excess ₱60,000.00 was misappropriated for personal use.
Aliga pleaded not guilty at arraignment on December 6, 1996.
Trial ensued with both parties presenting witnesses and documentary evidence.
The prosecution witnesses described the organizational structure of Dentrade Inc., roles of various employees, and detailed the handling of Villareal’s personal checks by Aliga and others.
Investigation involving the National Bureau of Investigation (NBI) led to discovery of the altered check and Aliga’s voluntary admission in handwriting, surrendering the ₱60,000.00.
Aliga claimed she was an accounting assistant, with limited custody of checks and no sole control over check preparation, asserting no exclusive responsibility for the altered check.
Dispute existed on whether Aliga was under custodial investigation when she gave her admission, and on the extent of the NBI’s involvement during the confrontation with Villareal.

Trial Court Decision

The Regional Trial Court (RTC), Branch 147, Makati City, found Aliga guilty beyond reasonable doubt of Qualified Theft through Falsification of Commercial Document.
The RTC sentenced her to an indeterminate penalty of 14 years and 8 months to 20 years of reclusion temporal.
The RTC absolved Aliga from civil liability as she had returned the ₱60,000.00.
The verdict extensively relied on the confession and other evidence pointing to Aliga’s guilt.

Court of Appeals Ruling

The Court of Appeals (CA) reversed and set aside the RTC’s conviction.
Key reasons for acquittal included:
- The alleged confession was inadmissible because Aliga was not informed of her constitutional rights during a custodial investigation.
- The evidence presented failed to overcome the presumption of innocence.
- The CA found the circumstantial evidence insufficient to warrant conviction beyond reasonable doubt.
The CA’s Resolution denied the petitioner’s motion for reconsideration.

Issues Raised in the Petition for Review on Certiorari

Whether the CA erred in declaring Aliga’s voluntary admission of guilt inadmissible, arguing that:
- An admission shifts the burden of proof to the defense to establish coercion or dur
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