GR 144118; (July, 2004) (Digest)
March 17, 2026GR 143866; (May, 2006) (Digest)
March 17, 2026G.R. No. 188694; February 12, 2014
RICARDO L. ATIENZA AND ALFREDO A. CASTRO, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioners Ricardo Atienza and Alfredo Castro, employees of the Court of Appeals (CA), were charged with Robbery and Falsification of a Public Document. The case stemmed from the discovery that a volume of CA Original Decisions (Volume 266) had been stolen and later returned with two spurious documents inserted: a resolution and a decision pertaining to the case of “Mateo Fernando v. Heirs of D. Tuason, Inc.” The NBI investigation confirmed the documents were forgeries and that the volume had been stolen by entering the CA Reporter’s Division through a hole in the wall after removing an air-conditioning unit. Evidence showed Atienza had previously offered money to the records custodian, Juanito Atibula, for another volume and was later heard berating him after the theft was reported. Castro was implicated for facilitating the return of the stolen volume via a co-worker.
ISSUE
The primary issue was whether the petitioners’ guilt for the crimes of Robbery and Falsification of Public Document was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the petitioners’ convictions. On the charge of Robbery, the Court found the evidence of conspiracy sufficient. The unlawful taking of the volume was established, and the acts of Atienza in attempting to bribe the custodian for a related volume and his subsequent outburst, coupled with Castro’s role in the volume’s clandestine return, demonstrated a community of criminal design. For Falsification of a Public Document under Article 172(1) in relation to Article 171(6) of the Revised Penal Code, the Court upheld the finding that the petitioners, as private individuals, altered a genuine public document by inserting forged resolutions. This alteration changed the document’s meaning, making it speak falsely about the legal status of the Fernando case. The Court rejected the petitioners’ defenses of denial and alibi, which were unsubstantiated and could not prevail over the positive evidence and credible testimony of the prosecution witnesses. The penalties imposed by the lower courts were affirmed as falling within the proper range provided by law.