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Legal Acquittal in Robbery Case

The Supreme Court acquitted petitioners Ricardo Atienza and Alfredo Castro of the crimes of robbery and falsification of public documents. While circumstantial evidence can be sufficient for conviction, the court found no evidence linking the petitioners to the commission of the crimes. Specifically, the only evidence that Castro possessed the missing public document came from a single witness statement, which was insufficient. The discrepancies in accounts diluted the strength of evidence required for conviction. At most, one petitioner's actions demonstrated interest in the subject matter but did not prove guilt beyond reasonable doubt. The petitioners were acquitted without prejudice to any administrative proceedings.

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Christopher Advincula
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3K views2 pages

Legal Acquittal in Robbery Case

The Supreme Court acquitted petitioners Ricardo Atienza and Alfredo Castro of the crimes of robbery and falsification of public documents. While circumstantial evidence can be sufficient for conviction, the court found no evidence linking the petitioners to the commission of the crimes. Specifically, the only evidence that Castro possessed the missing public document came from a single witness statement, which was insufficient. The discrepancies in accounts diluted the strength of evidence required for conviction. At most, one petitioner's actions demonstrated interest in the subject matter but did not prove guilt beyond reasonable doubt. The petitioners were acquitted without prejudice to any administrative proceedings.

Uploaded by

Christopher Advincula
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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RICARDO L. ATIENZA AND ALFREDO A.

CASTRO, Petitioners,
vs.
PEOPLE OF THE PHILIPPINES, Respondent
G.R. No. 188694
February 12, 2014

FACTS:
Petition for review on certiorari assailing the decision of the CA affirming
the decision of RTC Manila, finding petitioners Atienza and Castro guilty beyond
reasonable doubt of the crimes of Robbery and Falsification of Public Document.
Petitioners, Atienza and Castro are employees of the CA, Budget Officer I
and Utility Worker I, respectively. On March 20, 1995, Juanito Atibula (Atibula) a
custodian of the CA Original Decision was invited by Castro to attend Atienza’s
birthday party and was introduced to a certain Dario and asked him to assist in
searching for the CA decision.
Thereafter, Atibula returned to the office followed a few minutes later by
Dario and searched for the aforementioned decision, which was found compiled
in Volume 260 of the CA Original Decisions. On May 9, 1995, Atibula discovered
that Volume 266 was missing which he reported immediately to his superiors.
Few days later, a certain Nelson de Castro, also a CA employee, handed to
Atibula a bag containing a gift-wrapped package, which turned out to be the
missing Volume 266 and claimed that it was
Castro who asked him to do so.
The contents of the returned Vol. 266 were reviewed by atibula and it was
found that were two new documents inserted therein and that the duplicated
original decisions did not bear such promulgations. Upon the NBI investigations,
it was found that the Vol. 266 was indeed altered and the signature of the CA
justices therein have been forged.
A complaint was filed by the NBI to the office of the Ombudsman
implicating Atienza, Castro and Dario of the Crimes of Falsification of Public
Documents and Robbery under the RPC but Atienza denied the allegations.

ISSUE:
Whether or not petitioners’ conviction for the crimes of Robbery and
Falsification of Public Document should be upheld on account of the
circumstantial evidence proving their guilt beyond reasonable doubt.

RULING:
The petition is meritorious.
Circumstantial evidence consists of proof of collateral facts and
circumstances from which the main fact in issue may be inferred based on
reason and common experience.77 It is sufficient for conviction if: (a) there is
more than one circumstance; (b) the facts from which the inferences are derived
are proven; and (c) the combination of all the circumstances is such as to
produce a conviction beyond reasonable doubt.
The Court finds no evidence to link him to the commission of the crimes of
Robbery and Falsification of Public Document, contrary to the conclusions
reached by the RTC and concurred in by the CA. To begin with, it is essential to
note that Castro’s purported possession and eventual return of Volume 266 was
only premised upon the statement of one Nelson de Castro (Nelson) who averred
that to pass by his office and there handed him a bag which, as it turned out,
contained the missing Volume 266.
The discrepancy of accounts on the very subject matter of the crimes
charged dilutes the strength of the evidence required to produce a conviction. At
best, the bribery attempt may be deemed as a demonstration of interest on the
part of Atienza over said subject matter and in this regard, constitutes proof of
motive.
Accordingly, there being no circumstantial evidence sufficient to support a
conviction, the Court hereby acquits petitioners, without prejudice, however, to
any subsequent finding on their administrative liability in connection with the
incidents in this case.

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