Case Summary (G.R. No. 147839)
Key Dates
- Decision by Regional Trial Court: July 7, 2011
- Decision by Court of Appeals: July 15, 2013
- Resolution by Court of Appeals: January 8, 2014
- Supreme Court Decision: January 26, 2015
Applicable Law
The applicable law in this case is the Revised Penal Code, particularly Articles 308 and 309 concerning theft.
Facts of the Case
An Information was filed against Kyle Anthony Zabala, alleging theft of ₱68,000 belonging to Randolph Alas. The incident took place on June 18, 2007. The prosecution presented testimonies mainly from Alas and Piñon, while the defense relied on testimonies from Zabala and Ganas.
Version of the Prosecution
The prosecution established that Zabala, a jeepney driver, had a close relationship with Alas, who often invited him to his home. On the day of the theft, Alas left his house for work, only to return later that evening to find his money missing. Piñon testified that she witnessed Zabala climb the fence to enter Alas’s house and saw him come out with a bulge in his pocket, which she believed contained cash. Later, the couple went to purchase cellphones.
Version of the Defense
Zabala testified that he was occupied driving his jeepney and did not visit Alas’s home on the day in question. Ganas corroborated this, emphasizing that they spent the day together without dropping by Alas's house.
Ruling of the RTC
On July 7, 2011, the RTC convicted Zabala of theft based on the prosecution's evidence, sentencing him to imprisonment and ordering him to indemnify Alas for the stolen amount.
Ruling of the Court of Appeals
The CA upheld the RTC's decision on July 15, 2013, affirming that the prosecution established guilt beyond a reasonable doubt primarily through circumstantial evidence. The CA modified the penalty but maintained the conviction.
Issues Raised
- Whether the CA erred by giving full credence to the prosecution's testimonies.
- Whether the evidence on record supported a conviction.
Supreme Court's Analysis
The Supreme Court found that the evidence against Zabala was insufficient for a conviction beyond a reasonable doubt. It emphasized that while circumstantial evidence can lead to a conviction, it must form an unbroken chain leading dire
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Case Overview
- This case revolves around a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioner, Kyle Anthony Zabala, seeks to reverse the decision of the Court of Appeals (CA) dated July 15, 2013, and its resolution dated January 8, 2014.
- The CA decision upheld the Regional Trial Court (RTC) judgment convicting Zabala of theft, defined under Articles 308 and 309 of the Revised Penal Code.
Facts of the Case
- An Information was filed against Zabala for theft, alleging that on June 18, 2007, he unlawfully took PhP68,000.00 belonging to Randolph V. Alas.
- During the trial, Alas, the complainant, testified that he discovered the cash missing upon returning home from work that evening.
- Witness Marlyn PiAon, Zabala's then-girlfriend, testified that she saw Zabala enter Alas's house and later observed him with a bulge in his pocket.
- Zabala's defense included testimonies asserting that he was with a friend, Muriel John Ganas, and did not visit Alas's house.
Prosecution's Version
- The prosecution established that:
- Zabala was a jeepney driver with a modest income.
- Alas had saved the stolen amount through his job at the Manila City Hall.
- PiAon observed Zabala climbing the fence to enter Alas's home and later noticed his bulging pocket.
- After the incident, Zabala purchased two mobile phones, raising suspicions regarding the source of the money.
Defense's Version
- Zabala maintained his inn