Arriola vs. People

Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 10

Page 1 of 10

G.R. No. 217680. May 30, 2016.*


 
FELIX L. ARRIOLA, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
Remedial Law; Civil Procedure; Appeals; Petition for Review on Certiorari; As a general rule, a question of
fact is beyond the function of the Supreme Court (SC) in a petition for review under Rule 45 of the Rules of Court in
which only questions of law may be raised but there are exceptions.—At the outset, the respondent, through the Office
of the Solicitor General (OSG), has contended that the present petition should be dismissed on the ground that it raises
questions of fact. The contention is not persuasive. Indeed, as a general rule, a question of fact is beyond the function
of this Court in a petition for review under Rule 45 of the Rules of Court in which only questions of law may be raised
but there are exceptions. It is a settled doctrine that the factual findings of the appellate court are generally conclusive,
and even carry more weight when it affirms the findings of the trial court, absent any showing that the findings are
totally devoid of support in the record or that they are so glaringly erroneous as to constitute grave abuse of discretion.
Factual issues, however, may be resolved by this Court in the following instances: (1) the conclusion is a finding
grounded entirely on speculation, surmise and conjecture; (2) the inference made is manifestly mistaken; (3) there is
grave abuse of discretion; (4) the judgment is based on a misapprehension of facts; (5) the findings of fact are
conflicting; (6) the CA went beyond the issues of the case and its findings are contrary to the admissions of both
appellant and appellee; (7) the findings of fact of the CA are contrary to those of the trial court; (8) said findings of
fact are conclusions without citation of specific evidence on which they are based; (9) the facts set forth in the petition
as well as in the petitioner’s main and reply briefs are not disputed by the respondents; and (10) the findings of fact of
the CA are premised on the supposed absence of evidence and contradicted by the evidence on record.
_______________

*  SECOND DIVISION.

 
 
479
VOL. 791, MAY 30, 2016 479
Arriola vs. People
Same; Criminal Procedure; Prosecution of Offenses; Every criminal conviction requires the prosecution to
prove two (2) things: (1) the fact of the crime, that the presence of all the elements of the crime with which the
accused stands charged, and (2) the fact that the accused is the perpetrator of the crime.—Every criminal conviction
requires the prosecution to prove two things: (1) the fact of the crime, that the presence of all the elements of the crime
with which the accused stands charged, and (2) the fact that the accused is the perpetrator of the crime. When a crime
is committed, it is the duty of the prosecution to prove the identity of the perpetrator of the crime beyond reasonable
doubt for there can be no conviction even if the commission of the crime is established. In the case at bench, the State,
aside from showing the existence of the crime of falsification of public document, has the burden of correctly
identifying the author of such crime. Both facts must be proven beyond reasonable doubt on the strength of the
prosecution evidence and without solace from the weakness of the defense.
Same; Evidence; Circumstantial Evidence; The settled rule is that a judgment of conviction based purely on
circumstantial evidence can be upheld only if the following requisites concur: (1) there is more than one (1)
circumstance; (2) the facts from which the inferences are derived are proven; and (3) the combination of all the
circumstances is such as to produce conviction beyond reasonable doubt.—True, conviction is not always based on
direct evidence for it may also rest purely on circumstantial evidence. The settled rule is that a judgment of conviction
based purely on circumstantial evidence can be upheld only if the following requisites concur: (1) there is more than
one circumstance; (2) the facts from which the inferences are derived are proven; and (3) the combination of all the
circumstances is such as to produce conviction beyond reasonable doubt. The corollary rule is that the circumstances
proven must constitute an unbroken chain which leads to one fair and reasonable conclusion pointing to the accused,
to the exclusion of all others, as the guilty person. The circumstances proven must be consistent with each other,
consistent with the hypothesis that the accused is guilty and at the same time inconsistent with the hypothesis that he is
innocent and with any other rational hypothesis except that of guilt.
Same; Same; Same; The peculiarity of circumstantial evidence is that the series of events pointing to the
commission of a felony is
 
 
480
Page 2 of 10

480 SUPREME COURT REPORTS ANNOTATED


Arriola vs. People
appreciated not singly but collectively.—The peculiarity of circumstantial evidence is that the series of events
pointing to the commission of a felony is appreciated not singly but collectively. The guilt of the accused cannot be
deduced from scrutinizing just one (1) particular piece of evidence. It is more like a puzzle which when put together
reveals a convincing picture pointing to the conclusion that the accused is the author of the crime. Here, the story
pieced together by the RTC from the evidence of the prosecution provides no moral certainty of the petitioner’s guilt.
There is a paucity of evidence to show that Arriola had a direct hand in the falsification.
Same; Criminal Procedure; Prosecution of Offenses; Conviction must be based on the strength of the
prosecution and not on the weakness of the defense, that is the obligation is upon the shoulders of the prosecution to
prove the guilt of the accused and not the accused to prove his innocence.—Although the denial interposed by Arriola
is by nature a weak defense, the same is inconsequential as the prosecution failed to discharge the onus of establishing
his identity and culpability as the perpetrator. To reiterate, conviction must be based on the strength of the prosecution
and not on the weakness of the defense, that is the obligation is upon the shoulders of the prosecution to prove the
guilt of the accused and not the accused to prove his innocence. In other words, the prosecution has the burden to
prove that the accused is guilty beyond reasonable doubt of the crime charged.
Same; Same; Judgments; Courts must judge the guilt or innocence of the accused based on facts and not on
mere conjectures, presumptions, or suspicions.—Indeed, the presumption of innocence is not overcome by mere
suspicion or conjecture; by a probability that the accused committed the crime; or by the fact that he had the
opportunity to do so. Mere speculation and probabilities cannot substitute for proof required in establishing the guilt of
an accused beyond reasonable doubt. Courts must judge the guilt or innocence of the accused based on facts and not
on mere conjectures, presumptions, or suspicions.
PETITION for review on certiorari of the decision and resolution of the Court of Appeals.
The facts are stated in the opinion of the Court.
 
 
481
VOL. 791, MAY 30, 2016 481
Arriola vs. People
  Jennifer R. Santos for petitioner.
  Office of the Solicitor General for respondent.
MENDOZA, J.:
 
Before the Court is a petition for review on certiorari, filed by petitioner Felix L. Arriola (Arriola),
seeking to reverse and set aside the September 15, 2014 Decision 1 and the March 6, 2015 Resolution 2 of the
Court of Appeals (CA) in C.A.-G.R. CR No. 34921, which affirmed the Consolidated Judgment, 3 dated April
12, 2012, of the Regional Trial Court, Branch 17, Manila, in twenty-one (21) falsification of public
document cases.

The Antecedents
 
Petitioner Arriola and Ma. Theresa Tabuzo (Tabuzo), a.k.a. Girlie Moore (Tabuzo) were indicted for
twenty-one (21) counts of Falsification of Public Document, defined and penalized under Article 171 of the
Revised Penal Code (RPC). The 21 separate Informations4 filed against Arriola and Tabuzo were
consolidated before the RTC and docketed as Criminal Case Nos. 03-219432 to 03-219452.
Arriola voluntarily surrendered and was allowed to post bail for his provisional liberty. 5 When arraigned
on May 27, 2004, he entered a plea of not guilty to the charges. 6 Meanwhile, Tabuzo was finally
apprehended on June 14, 2004 and
_______________

1  Penned by Associate Justice Japar B. Dimaampao, with Associate Justices Elihu A. Ybañez and Carmelita S. Manahan,
concurring; Rollo, pp. 90-103.
2  Id., at pp. 105-106.
3  Penned by Acting Presiding Judge Ma. Theresa Dolores C. Gomez-Estoesta; id., at pp. 75-88.
Page 3 of 10

4  Records, pp. 2-43.


5  Id., at p. 102.
6  Id., at p. 139.

 
 
482
482 SUPREME COURT REPORTS ANNOTATED
Arriola vs. People
upon arraignment, she also pleaded not guilty to the charges. 7 Tabuzo was subsequently released on the
basis of a personal bail which she posted on November 5, 2004.8 During the pretrial for Arriola, the parties
stipulated, among others, that he was an employee of the Manila City Hall. 9 The pretrial for Tabuzo was
terminated10 because of her nonappearance. Considering that Tabuzo absconded, trial in absentia proceeded
against her.
As synthesized by the RTC, the facts are as follows:
 
In the year 2002, Gregg Business Agency, a local accounting firm, needed to procure community
tax certificates (CTCs) for twenty-one (21) of its clients. It then appeared that Rosalinda Pagapong
(Pagapong), its Liaison Officer, was instructed by the owner to coordinate with a certain “Girlie
Moore” to obtain the same. This was the same “Girlie Moore” who personally visited the accounting
firm on January 17, 2002 to get the names of the clients after receiving a total amount of P38,500.00
to process the CTCs. She promised that she will deliver the CTCs by January 19, 2002.
However, it was only on January 31, 2002, after frequent follow-ups, that Pagapong was able to
obtain from “Girlie Moore” the CTCs. They met at the Inner Court of the Manila City Hall located at
the ground floor. A soon as Pagapong received the CTCs, she proceeded to the Releasing Area of the
Office of the City Treasurer to secure an Order of Payment and presented the CTCs as a requirement.
It was at such instance that, upon verification, the CTCs were found to be fake or falsified. Pagapong
was thereafter subjected to investigation at the Office of the City Treasurer.
At around 4:30 in the afternoon of the same day, Liberty M. Toledo, then the City Treasurer of
Manila,
_______________

7   Id., at p. 186.
8   Id., at p. 189.
9   Id., at p. 275.
10  Id., at p. 308.

 
 
483
VOL. 791, MAY 30, 2016 483
Arriola vs. People
was apprised of the falsified CTCs with Serial Nos. 15492830 to 15492850 found in the possession
of Pagapong. The CTCs bearing the same serial numbers were counter-checked from the files of the
Office of the City Treasurer and were found to have been actually stamped as “UNEMPLOYED”
under “MANILA, CLASS A — ONLY,” having been issued to unemployed residents of the City of
Manila for a fee of P5.00 each. Further verification from the records disclosed that the CTCs with the
same serial numbers were requisitioned by and issued to Felix Arriola, Local Treasury Operations
Officer I of the Office of the City Treasurer of Manila. A subsequent inquiry with Pagapong revealed
that the CTCs were obtained from “Girlie Moore.” Another verification with the Department of Public
Services (DPS) revealed that the woman who posed as “Girlie Moore” was actually Ma. Theresa
Tabuzo, then employed as Manila Aide I assigned at District 4 of the City of Manila.
The requisition of Community Tax Certificates in the name of accountable officer Felix L. Arriola
was the subject of stipulation between the prosecution and the defense per Order, dated September 20,
2006 which stated, in lieu of the intended testimony of prosecution witness Priscilla M. Panganiban,
OIC of the Accountable Forms Section of the Office of the City Treasurer of Manila, viz.:
Page 4 of 10

x x x x x x x x x x x x
2. x x x that on January 18, 2002, accused Felix Arriola was issued one thousand pieces of
Community Tax Certificates “A” as evidenced by his signature on the Requisition Form dated
January 18, 2002;
3. x x x per Accountable Forms Control Card, accused Felix Arriola was issued
Community Tax Certificates “A” on January 18, 2002, one thousand pieces, with Serial Nos.
15492401 to 15493400, inclusive;
4. that accused Felix Arriola remitted on January 21, 2002 the triplicate copies of
 
 
484
484 SUPREME COURT REPORTS ANNOTATED
Arriola vs. People
the Community Tax Certificate “A” Nos. 15492601 to 15492900, which were issued to him on
January 18, 2002; and
5. x x x the triplicate copies of the Community Tax Certificate Nos. 15492801 to
15492850 were remitted by accused Felix Arriola on January 21, 2002 and these were all Class
A Community Tax Certificates.
    The supposed presentation of prosecution witness Evelyn Uy was considered waived in view of
her nonappearance during the hearing of April 16, 2009.
x x x x
For his defense, accused Felix L. Arriola interposed the defense of denial.
Accused Arriola averred that he is presently employed as Revenue Examiner of the Office of the
City Treasurer of Manila tasked with the duty of computing business taxes and collecting tax
deficiencies. In the course of his employment as such, he denied having known the person of Ma.
Theresa Tabuzo nor of having participated in the falsification of CTCs which specifically implicated
Ma. Theresa Tabuzo.
In the year 2002, he admitted to have occupied the position of an accountable officer who held the
responsibility of requisitioning CTCs. He had five (5) employees then under him who issued the CTCs
to individual taxpayers and it was to them that he gave the CTC booklets for such purpose. Such
booklets were under Class “A” at the cost of P5.00 each. He further averred that after receiving the
amount of P250.00 from each booklet from the collectors, he immediately remitted the same to the
Office of the City Treasurer.
On January 28, 2002, he recounted that Community Tax Certificate No. 15492830 was issued by
Elena Ronquillo as the booklet which contained the same was given to said Elena Ronquillo. The
booklets which were returned to him no longer contained the originals thereof as what was returned
were the duplicate and triplicate copies; hence, he had no control in the issuance of the originals. From
his assessment of the duplicate and triplicate
 
 
485
VOL. 791, MAY 30, 2016 485
Arriola vs. People
copies of the booklets, he found no unusual alterations of any portions thereof. When he was thus
summoned for questioning by Ms. Rosalie Reyes, OIC of the Administrative Division, he denied any
implication in the issuance of falsified CTCs. He likewise denied having written the entries in the
questioned CTCs. He endeavored to ask Elena Ronquillo of the purported anomaly but the latter also
denied knowledge of the same. He likewise denied having known Rosalinda Pagapong.11

The Ruling of the RTC


 
On April 12, 2012, the RTC rendered its consolidated judgment finding Arriola and Tabuzo guilty as
charged. It concluded that the prosecution had satisfactorily proven all the elements of the crime of
Page 5 of 10

Falsification of Public Document. The RTC stated that, although there was no direct evidence linking
Arriola to the commission of the crime, adequate circumstantial evidence was adduced by the prosecution
which established with moral certainty that he was the perpetrator of the alterations in the subject CTCs
bearing Control Nos. 15492830 to 15492850 marked as Exhibits “A” to “A-20.” 12 With regard to Tabuzo,
the Court found that she acted as the courier in delivering the falsified CTCs to the requesting party. The
RTC added that the manner by which the two accused committed the felonious acts revealed a community
of criminal design, and so it eventually concluded that conspiracy existed. It brushed aside Arriola’s defense
of denial for his failure to substantiate the same by sufficient and competent evidence.
Not in conformity, Arriola appealed the RTC judgment of conviction before the CA.
_______________

11  Id., at pp. 78-81.


12  Id., at pp. 620-630.

 
 
486
486 SUPREME COURT REPORTS ANNOTATED
Arriola vs. People
The Ruling of the CA
 
In its assailed September 15, 2014 decision, the CA found no cogent reason to reverse the findings of
facts and conclusions reached by the RTC and, thus, affirmed the conviction of Arriola and Tabuzo for 21
counts of the crime of falsification of public document. The CA wrote that the evidence proffered by the
prosecution had established with certitude the commission of the offense and the identities of its culprits. At
the end, the CA decreed:
 
WHEREFORE, the Appeal is hereby DENIED. The Consolidated Judgment dated 12 April 2012
of the Regional Trial Court of Manila, Branch 17, in Criminal Case Nos. 03-219433-03-219452, is
AFFIRMED.
SO ORDERED.13
 
Arriola moved for reconsideration of the September 15, 2014 decision, but his motion was denied by the
CA in its March 6, 2015 Resolution.
Insisting on his innocence, Arriola elevated the decision of the CA via a petition for review
on certiorari to this Court and raised the following:
Issues
 
A. The evidence for the prosecution failed to establish the guilt of petitioner beyond
reasonable doubt.14
B. The authorities cited to support the conviction of petitioner are not applicable. 15
_______________

13  Rollo, p. 102.
14  Id., at p. 11.
15  Id., at p. 15.

 
 
487
VOL. 791, MAY 30, 2016 487
Arriola vs. People
The Court’s Ruling
 
The Court gives the benefit of the doubt to the accused.
Page 6 of 10

At the outset, the respondent, through the Office of the Solicitor General (OSG), has contended that the
present petition should be dismissed on the ground that it raises questions of fact. The contention is not
persuasive. Indeed, as a general rule, a question of fact is beyond the function of this Court in a petition for
review under Rule 45 of the Rules of Court in which only questions of law may be raised but there are
exceptions. It is a settled doctrine that the factual findings of the appellate court are generally conclusive,
and even carry more weight when it affirms the findings of the trial court, absent any showing that the
findings are totally devoid of support in the record or that they are so glaringly erroneous as to constitute
grave abuse of discretion.16 Factual issues, however, may be resolved by this Court in the following
instances: (1) the conclusion is a finding grounded entirely on speculation, surmise and conjecture; (2) the
inference made is manifestly mistaken; (3) there is grave abuse of discretion; (4) the judgment is based on a
misapprehension of facts; (5) the findings of fact are conflicting; (6) the CA went beyond the issues of the
case and its findings are contrary to the admissions of both appellant and appellee; (7) the findings of fact of
the CA are contrary to those of the trial court; (8) said findings of fact are conclusions without citation of
specific evidence on which they are based; (9) the facts set forth in the petition as well as in the petitioner’s
main and reply briefs are not disputed by the respondents; and (10) the findings of fact of the CA are
premised on the supposed absence of evidence and contradicted by the evidence on record.17
_______________

16  Libuit v. People, 506 Phil. 591, 599; 469 SCRA 610, 618 (2005).
17  Cornes v. Leal Realty Centrum Co., Inc., 582 Phil. 528, 549; 560 SCRA 545, 567 (2008).

 
 
488
488 SUPREME COURT REPORTS ANNOTATED
Arriola vs. People
In the case at bench, the CA concurred with the findings of fact by the RTC that were based on
circumstantial evidence. For said reason, the Court is compelled to review the evidence on record as the
findings were merely deduced from several circumstances.
Every criminal conviction requires the prosecution to prove two things: (1) the fact of the crime, that the
presence of all the elements of the crime with which the accused stands charged, and (2) the fact that the
accused is the perpetrator of the crime.18 When a crime is committed, it is the duty of the prosecution to
prove the identity of the perpetrator of the crime beyond reasonable doubt for there can be no conviction
even if the commission of the crime is established. 19 In the case at bench, the State, aside from showing the
existence of the crime of falsification of public document, has the burden of correctly identifying the author
of such crime. Both facts must be proven beyond reasonable doubt on the strength of the prosecution
evidence and without solace from the weakness of the defense.20
The Court pored over the entire records of both courts a quo and concluded that Arriola should be
exonerated. Contrary to the findings by the RTC, the circumstantial evidence adduced by the prosecution
failed to evoke the moral certainty that the petitioner was guilty.
Clearly, there is no direct evidence that links Arriola to the commission of the crime. As the RTC itself
stated, “[a]lthough no eyewitness could particularly delineate the particular scheme or method used in the
falsification of subject CTCs, the vestiges of all alterations made thereon could only be pinned down to the
public accountability of accused Felix L. Arriola and his complicity with known fixer, ‘Girlie Moore,’
_______________

18  People v. Ayola, 416 Phil. 861, 871; 364 SCRA 451, 460 (2001).
19  People v. Sinco, 408 Phil. 1, 12; 355 SCRA 713, 721 (2001).
20  People v. Limpangog, 444 Phil. 691, 709; 396 SCRA 603, 618 (2003).

 
 
489
VOL. 791, MAY 30, 2016 489
Arriola vs. People
Page 7 of 10

otherwise identified as accused Ma. Theresa Tabuzo.”21 The RTC was, thus, compelled to rely solely on
the following pieces of circumstantial evidence which appeared to have been established to justify its
finding of guilt:
 
1) That on January 18, 2002, Arriola requisitioned from the Accountable Forms Section of the Office of
the City Treasurer of Manila the issuance of One Thousand (1,000) pieces of Class A CTCs as evidenced by
his signature appearing on the Requisition Slip,22 dated January 18, 2002, marked as Exhibit “J” for the
prosecution;
2) That as shown in the Accountable Forms Control Card,23 marked as Exhibit “K” for the prosecution,
Arriola was issued One Thousand (1,000) pieces of Class A CTCs with inclusive control numbers from
15492401 to 15493400;
3) That Class A CTCs were issued only to unemployed residents of the City of Manila for a standard fee
of P5.00 each;
4) That on January 21, 2002, Arriola remitted the amount of P1,500.00 representing the collection for the
issued Class A CTC Nos. 15492601 to 15492900 as well as the triplicate copies thereof;
5) That the collection for the triplicate copies of CTC Nos. 15492830 to 15492850 24 were among those
remitted by Arriola on January 21, 2002 and these were all Class A CTCs;
6) That on January 31, 2002, Tabuzo delivered to Rosalinda Pagapong (Pagapong), the Liaison Officer
of Gregg Business Agency, the CTCs with
_______________

21  Rollo, p. 81.
22  Records, p. 642.
23  Id., at pp. 643-644.
24  Id., at pp. 631-637.

 
 
490
490 SUPREME COURT REPORTS ANNOTATED
Arriola vs. People
control numbers 15492830 to 15492850, now categorized as Class B CTCs because a higher fee
was charged for each CTC ranging from P143.00 to P5,005.00, depending on the declared taxable
income of the taxpayers.
7) That Gregg Business Agency paid Tabuzo the amount of P38,500.00 for securing the latter
CTCs;
8) That the CTCs found in the possession of Pagapong were fake as the CTCs bearing the same
control numbers had already been issued to unemployed residents of Manila per files of the Office of
the City Treasurer.
 
The Court cannot fully agree with the RTC and the CA that the foregoing pieces of circumstantial
evidence inexorably led to the conclusion that the petitioner falsified the subject CTCs.
True, conviction is not always based on direct evidence for it may also rest purely on circumstantial
evidence. The settled rule is that a judgment of conviction based purely on circumstantial evidence can be
upheld only if the following requisites concur: (1) there is more than one circumstance; (2) the facts from
which the inferences are derived are proven; and (3) the combination of all the circumstances is such as to
produce conviction beyond reasonable doubt.25 The corollary rule is that the circumstances proven must
constitute an unbroken chain which leads to one fair and reasonable conclusion pointing to the accused, to
the exclusion of all others, as the guilty person.26 The circumstances proven must be consistent with each
other, consistent with the hypothesis
_______________

25  Section 4, Rule 133 of the Rules of Court, People v. Canlas, 423 Phil. 665, 677; 372 SCRA 401, 411 (2001).
26  People v. Flores, 389 Phil. 532, 541; 328 SCRA 461, 469 (2000).

 
Page 8 of 10

 
491
VOL. 791, MAY 30, 2016 491
Arriola vs. People
that the accused is guilty and at the same time inconsistent with the hypothesis that he is innocent and
with any other rational hypothesis except that of guilt.27
On the basis of these principles, the Court is of the view that the circumstantial evidence cited by the
RTC raised doubt as to the guilt of Arriola. The circumstantial evidence of the prosecution failed to muster
the quantum of proof required in criminal cases — guilt beyond reasonable doubt. Moreover, the
circumstances enumerated by the trial court did not completely discount the possibility that other than the
petitioner, another person or persons could have falsified the subject CTCs.
The prosecution’s principal witness, Liberty M. Toledo (Toledo), the City Treasurer of Manila at the time
of the incident, testified that she merely presumed that Arriola conspired and connived with Tabuzo in the
falsification because he was the accountable officer who requisitioned for the booklets containing the
falsified CTCs. Toledo claimed that the accountable officer should be held liable for any alterations done on
the subject CTCs.28 Lending much weight on Toledo’s testimony, the RTC concluded that because Arriola
was the accountable officer who requisitioned the subject CTCs, then he “is the only person who could have
accomplished the crimes charged.”29 Thus, the RTC wrote:

Co-accused Ma. Theresa Tabuzo, being a mere Manila Aide 1 from the Department of Public
Service, could not be isolated for having alone committed the crimes charged. Obviously, she has no
direct hand in the requisitioning and issuance of community tax certificates from the Office of the City
Treasurer. An insider would have
_______________

27  People v. Abillar, 400 Phil. 245, 249; 346 SCRA 433, 435 (2000).
28  TSN dated August 17, 2006, pp. 17-20.
29  Rollo, p. 81.

 
 
492
492 SUPREME COURT REPORTS ANNOTATED
Arriola vs. People
accomplished the falsifications. It would, therefore, summon a conspiratorial act to accomplish the
misdeed.
With the connection of accused Felix L. Arriola with the Cash Division of the Office of the City
Treasurer of Manila, it did not take a fertile imagination to extend his complicity of the crime to that
of co-accused Ma. Theresa Tabuzo.
x x x x
In this case, the intolerable delay in the delivery of subject CTCs by accused Ma. Theresa Tabuzo
to Gregg Business Agency could only explain her dependency on the complicity of another connected
with the Office of the City Treasurer. As already adverted to, she could not possibly commit the
crimes alone. It then highly appeared that the falsification was traced to the accountability of accused
Felix L. Arriola who, by his own sordid means, must have duplicated the Class A CTCs with serial
numbers 15492830-check to 15492850-check to misrepresent them as Class B CTCs.30
[Emphases supplied]
 
The conclusion by the RTC that Arriola was the perpetrator of the falsification simply because the
booklet, which contained the Class A CTCs bearing control numbers 15492830 to 15492850, was among
those issued to him upon his request was speculative. It must be stressed that the subject CTCs found in the
possession of Pagapong were different from, and were mere replicas or imitations of, the Class A CTCs with
Serial Numbers 15492830 to 15492850. This is evident from the fact that the Class A CTCs were already
Page 9 of 10

issued to the unemployed residents of Manila on January 21, 2002 while those handed over by Tabuzo to
Pagapong were issued much later or on January 28, 2002. Not a shred of definitive evidence was proffered
by the prosecution to prove that Arriola, between the time he received the booklets of CTCs on Janu-
_______________

30  Id., at pp. 84-85.

 
 
493
VOL. 791, MAY 30, 2016 493
Arriola vs. People
ary 18, 2002 and before their issuance to the unemployed residents of Manila, had the Class A CTCs
with control numbers 15492830 to 15492850 duplicated or copied and that, thereafter, supplied the details
written on the CTCs found in the possession of Pagapong. There is absolutely no proof of what transpired
during that interval. The prosecution, in effect, asked the courts merely to guess or to surmise that A must
have falsified the Class A CTCs during such interregnum.
There was no showing either that the replicas of the Class A CTCs with control numbers 15492830 to
15492850, which Tabuzo delivered to Pagapong, came from Arriola, or that he was the one who actually
made the duplicates. These gaps in the prosecution account spawn doubts in the mind of a reasonable
person. Verily, there was no concrete prosecution evidence that would link Arriola to the falsification.
The peculiarity of circumstantial evidence is that the series of events pointing to the commission of a
felony is appreciated not singly but collectively. The guilt of the accused cannot be deduced from
scrutinizing just one (1) particular piece of evidence. It is more like a puzzle which when put together
reveals a convincing picture pointing to the conclusion that the accused is the author of the crime. 31 Here, the
story pieced together by the RTC from the evidence of the prosecution provides no moral certainty of the
petitioner’s guilt. There is a paucity of evidence to show that Arriola had a direct hand in the falsification.
In light of the blurry evidence of the prosecution, the possibility that another person or persons could
have authored the crime cannot be totally discounted. Records do not show that after Arriola received the
Class A CTCs from the Accountable Forms Section of the Office of the City Treasurer, he immediately put
them in a place not accessible to anyone but himself.
_______________

31  People v. Monje, 438 Phil. 716, 733; 390 SCRA 160, 177 (2002).

 
 
494
494 SUPREME COURT REPORTS ANNOTATED
Arriola vs. People
It must be remembered that Arriola had five (5) subordinates who were tasked with the duty of issuing
the Class A CTCs to the public. Anyone of these five subordinates could have gotten hold of the booklet
containing the Class A CTCs with control numbers 15492830 to 15492850 and had them duplicated or
copied. Circumstantial evidence must exclude the possibility that some other person had committed the
offense.32 The absence of evidence as to the non-accessibility of the CTCs precludes the Court from
concluding with certainty that no other person or persons, aside from Arriola, could be the culprit in the
falsification. The evidence at hand neither proves his authorship of the crime nor forecloses the possibility
that another person is liable.
Although the denial interposed by Arriola is by nature a weak defense, the same is inconsequential as the
prosecution failed to discharge the onus of establishing his identity and culpability as the perpetrator. To
reiterate, conviction must be based on the strength of the prosecution and not on the weakness of the
defense, that is the obligation is upon the shoulders of the prosecution to prove the guilt of the accused and
not the accused to prove his innocence. 33 In other words, the prosecution has the burden to prove that the
accused is guilty beyond reasonable doubt of the crime charged.
Page 10 of 10

Indeed, the presumption of innocence is not overcome by mere suspicion or conjecture; by a probability
that the accused committed the crime; or by the fact that he had the opportunity to do so. Mere speculation
and probabilities cannot substitute for proof required in establishing the guilt of an accused beyond
reasonable doubt.34 Courts must judge the
_______________

32  Supra note 18 at pp. 873-874; p. 462.


33  People v. Galvez, 548 Phil. 436, 470; 519 SCRA 521, 551 (2007).
34  People v. Canlas, supra note 25 at pp. 684-685; p. 418.

 
 
495
VOL. 791, MAY 30, 2016 495
Arriola vs. People
guilt or innocence of the accused based on facts and not on mere conjectures, presumptions, or suspicions.35
It could be that Arriola had actually participated in the commission of the crime. The Court, however,
cannot convict him when the circumstantial evidence relied upon by the RTC and subscribed to by the CA is
plainly inadequate and unconvincing. Thus, it cannot be said that the prosecution was able to prove his guilt
beyond reasonable doubt.
 
x x x And where there is a reasonable doubt as to the guilt of an accused, he must be acquitted
even though his innocence may be questioned, for it is not sufficient for the proof to establish a
probability, even though strong, that the fact charged is more likely to be true than the contrary. Proof
beyond reasonable doubt, more than mere likelihood, requires moral certainty — a certainty that
convinces and satisfies the reason and conscience of those who are to act upon it.36
 
WHEREFORE, the petition is GRANTED.
The September 15, 2014 Decision and the March 6, 2015 Resolution of the Court of Appeals in C.A.-
G.R. CR No. 34921, which affirmed the April 12, 2012 Consolidated Judgment of the Regional Trial Court,
Branch 17, Manila, in Criminal Case Nos. 03-219432 to 03-219452, are REVERSED and SET ASIDE.
Petitioner Felix L. Arriola is ACQUITTED, for failure of the prosecution to prove his guilt beyond
reasonable doubt, of Twenty-One (21) counts of Falsification of Public Document.
SO ORDERED.
_______________

35  Crisostomo v. Sandiganbayan, 495 Phil. 718; 456 SCRA 45 (2005).


36  Ambagan, Jr. v. People, G.R. Nos. 204481-82, October 14, 2015, 772 SCRA 489.

 
 
496
496 SUPREME COURT REPORTS ANNOTATED
Arriola vs. People
Carpio (Chairperson), Brion, Del Castillo  and Leonen, JJ., concur.
Petition granted, judgment and resolution reversed and set aside.
Notes.—Circumstantial evidence, also known as indirect or presumptive evidence, consists of proof of
collateral facts and circumstances from which the existence of the main fact may be inferred according to
reason and common experience. (People vs. Nuyok, 757 SCRA 480 [2015])
Circumstantial evidence consists of proof of collateral facts and circumstances from which the existence
of the main fact may be inferred according to reason and common experience. (People vs. Broniola, 760
SCRA 597 [2015])

You might also like

pFad - Phonifier reborn

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.

Note: This service is not intended for secure transactions such as banking, social media, email, or purchasing. Use at your own risk. We assume no liability whatsoever for broken pages.


Alternative Proxies:

Alternative Proxy

pFad Proxy

pFad v3 Proxy

pFad v4 Proxy