CASE DIGEST : Daniel G. Imperial v. People of the Philippines G.R. No. 230519, June 30, 2021 GAERLAN

 

FACTS

Daniel G. Imperial was employed as the Head of the Maintenance Department of Now Trading Concept Multi-Purpose Cooperative (NTC-MPC). Because of the nature of his position, he was entrusted with custody and supervision of maintenance materials and equipment owned by the cooperative. On April 21, 2008, Imperial requested the purchase of one roll of Royal Cord No. 14/3 wire, 75 meters in length, which was intended for the repair of a wash tub and dryer at the company warehouse. The item was purchased and delivered to the cooperative.

Later, NTC-MPC discovered that the Royal Cord No. 14/3 wire could not be found. The company investigated and confronted Imperial because he was the person who requested the purchase and had custody over the maintenance materials. Imperial claimed that he discovered the missing wires inside a company vehicle and returned them to the warehouse. However, the company alleged that the wire he returned was a different specification (Royal Cord No. 16/2) and accused him of taking the original wire for his own benefit.

Imperial was subsequently terminated and charged with qualified theft under Article 310 in relation to Article 308 of the Revised Penal Code (RPC). The Regional Trial Court (RTC) found him guilty beyond reasonable doubt and ruled that the prosecution had established that he took the property entrusted to him with intent to gain and with grave abuse of confidence. The Court of Appeals (CA) affirmed the conviction, holding that the evidence sufficiently showed that Imperial was the last person responsible for the missing wire.

Imperial elevated the case to the Supreme Court through a Petition for Review on Certiorari under Rule 45 of the Rules of Court. He argued that the prosecution failed to prove that he actually took the wire and that the evidence presented was merely circumstantial. The Supreme Court was tasked to determine whether the evidence was sufficient to establish his guilt beyond reasonable doubt.

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ISSUE

Whether Daniel Imperial was guilty beyond reasonable doubt of qualified theft under Article 310 in relation to Article 308 of the Revised Penal Code.

Whether the circumstantial evidence presented by the prosecution was sufficient to establish that Imperial unlawfully took the property of NTC-MPC with intent to gain and with grave abuse of confidence.

Whether the Court of Appeals correctly affirmed the RTC’s conviction despite the absence of direct evidence proving that Imperial took the missing wire.

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HELD

The Supreme Court GRANTED the petition and ACQUITTED Daniel Imperial on the ground of reasonable doubt. The Court held that the prosecution failed to establish all the elements of qualified theft under Article 310 in relation to Article 308 of the Revised Penal Code. Theft requires: (1) taking of personal property; (2) that the property belongs to another; (3) that the taking was done with intent to gain; (4) absence of the owner’s consent; (5) taking without violence, intimidation, or force upon things; and (6) in qualified theft, the presence of grave abuse of confidence.

The Court explained that the prosecution failed to prove the corpus delicti of the crime. In theft cases, corpus delicti requires proof that the property was actually lost through a felonious taking. While it was established that the Royal Cord No. 14/3 wire was missing, the prosecution failed to prove that Imperial was the person who unlawfully took it. The Court emphasized that suspicion, even if strong, cannot replace proof beyond reasonable doubt required in criminal cases.

The Supreme Court further ruled that although a conviction may be based on circumstantial evidence, such evidence must satisfy Section 4, Rule 133 of the Rules of Court, requiring: (1) there must be more than one circumstance; (2) the facts from which the inferences are derived must be proven; and (3) the combination of all circumstances must produce conviction beyond reasonable doubt. In this case, the circumstances relied upon by the prosecution were insufficient because they did not exclude the possibility that another person could have taken or misplaced the wire.

The Court noted several circumstances creating reasonable doubt. Imperial openly directed company personnel to the location where he allegedly found the wires, which was inconsistent with an attempt to conceal theft. Moreover, questions remained as to why he would take a Royal Cord No. 14/3 wire only to replace it with a different type of wire. These circumstances weakened the prosecution’s theory that Imperial intended to gain from the alleged taking.

The Supreme Court reiterated the constitutional principle that an accused is presumed innocent until proven guilty beyond reasonable doubt. The prosecution must rely on the strength of its own evidence and not on the weakness of the defense. Since the evidence failed to establish that Imperial committed the unlawful taking, the Court reversed the decisions of the RTC and CA and acquitted him of qualified theft.

Doctrine: In criminal cases, circumstantial evidence may support conviction, but it must form an unbroken chain leading exclusively to the guilt of the accused. Where reasonable doubt exists regarding the identity of the offender or the commission of the unlawful taking, acquittal must follow.