Case Summary (G.R. No. 209373)
Facts of the Case
The case arose from allegations against the petitioners, who were employees of the City Government of Iligan—Tangian as a garbage truck driver, and Yongco and LaAojan as security guards. An information charging them with qualified theft was filed on November 14, 2005, stating that they unlawfully took car parts belonging to the City Government with a total value of PHP 40,000. After their arrest and subsequent trial, the Regional Trial Court (RTC) found them guilty, prompting a series of appeals that culminated in the decision from the Court of Appeals affirming the RTC's ruling.
Prosecution's Version
The prosecution's case relied on testimonies from city government employees, including Pablo Salosod, who stated that on April 16, 2005, Tangian requested him to accompany him to the City Engineer's Office (CEO) during the early hours. Salosod claimed that they loaded car parts, deemed as waste by the petitioners, onto Tangian’s truck and later unloaded these items at a junk store. Other witnesses corroborated Salosod's account and provided evidence pertaining to the investigation conducted that led to the filing of charges against the petitioners.
Defense's Version
In their defense, each petitioner testified to assert that they acted innocently under the belief that the items they handled were properly authorized for removal. Yongco argued that he had received gate passes and that they were merely doing their duty to clear scrap materials as directed. LaAojan maintained that he was not present during the alleged theft, while Tangian insisted that he was just following LaAojan’s instructions, believing there were no issues with the items being taken.
Ruling of the Regional Trial Court
The RTC convicted the petitioners on April 11, 2008, finding them guilty of qualified theft via conspiracy. The court emphasized that the evidence established the elements of theft, particularly highlighting the grave abuse of confidence given their positions. Each petitioner received sentences ranging from six years and eight months to ten years and eight months of imprisonment.
Ruling of the Court of Appeals
On January 21, 2013, the Court of Appeals affirmed the RTC's decision, recognizing the existence of conspiracy among the petitioners, noting that Tangian could not have removed the items without Yongco's participation as a security guard. The CA found that the thumb-up sign given by LaAojan was indicative of a coordinated effort. A motion for reconsideration by the petitioners was subsequently denied on September 10, 2013.
The Issue
The primary issue presented in the consolidated petitions revolved around whether the Court of Appeals erred in upholding the petitioners’ conviction for qualified theft, particularly regarding the established conspiracy and the petitioners’ claims of a lack of criminal intent.
The Court’s Ruling
The Supreme
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Case Overview
- This case involves consolidated Petitions for Review on Certiorari under Rule 45 in relation to Rule 125 of the Rules of Court.
- Petitioners Joel Yongco, Julieto LaAojan, and Anecito Tangian, Jr. were convicted of qualified theft by the Regional Trial Court (RTC) and their conviction was affirmed by the Court of Appeals (CA).
- The case was decided by the Third Division of the Supreme Court on July 30, 2014.
Background of the Case
- The petitioners were employees of the City Government of Iligan: Tangian was a garbage truck driver, while Yongco and LaAojan were security guards at the City Engineer's Office (CEO).
- They were charged with qualified theft for allegedly stealing car parts valued at P40,000.00 from the CEO.
- The Information was filed on November 14, 2005, with the actual alleged theft occurring on April 16, 2005.
- During the arraignment on February 16, 2006, the petitioners pleaded not guilty.
Allegations and Evidence Presented by the Prosecution
- Witness Pablo Salosod testified that on the night of the alleged theft, Tangian asked him to help load what they believed were waste items onto the truck.
- The items were taken to Delfin Junk Store, where LaAojan was seen giving a thumbs-up signal to Tangian, indicating approval of the action.
- Other witnesses corroborated Salosod's testimony regarding the loading and unloading of the stolen it