G.R. No. 234023 . September 03, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JENNIE MANLAO Y LAQUILA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Jennie Manlao was employed as a housemaid by spouses Carmel and Alessandro Villaraza. On July 1, 2011, co-housemaid Geralyn Noynay observed Jennie acting suspiciously after a phone call. Jennie claimed their employers had met an accident and that she was instructed to retrieve dollars. Geralyn witnessed Jennie forcibly open a locked drawer in the master’s bathroom using tools. Jennie subsequently took numerous pieces of jewelry from the drawer, left the house with them, and later claimed she gave the items to an unidentified woman in Caloocan. Upon discovering the theft, the employers confronted Jennie at their home, where she admitted to taking the jewelry. She was charged with Qualified Theft for items valued at P1,849,000.00.
The Regional Trial Court convicted Jennie of Qualified Theft. On appeal, she argued that the prosecution failed to prove the elements of the crime, particularly the taking without consent and the value of the stolen items, and claimed her extrajudicial confession was inadmissible. The Court of Appeals affirmed the conviction but reduced the awarded actual damages to P1,189,000.00 based on the evidence presented. Jennie elevated the case to the Supreme Court via an ordinary appeal.

ISSUE

Whether the Court of Appeals correctly affirmed accused-appellant Jennie Manlao’s conviction for the crime of Qualified Theft.

RULING

Yes, the Supreme Court affirmed the conviction with modifications. The Court held that all elements of Qualified Theft were established beyond reasonable doubt. The taking of the jewelry was proven through the credible testimony of eyewitness Geralyn Noynay, who saw Jennie forcibly open the drawer and take the items. Jennie’s own judicial confession to her employers upon being confronted corroborated this. The element of grave abuse of confidence was present due to her position as a live-in housemaid with free access to the household, including the master’s bedroom. Intent to gain was inferred from her acts of taking and disposing of the property.
The Court rejected Jennie’s defenses. Her claim of being deceived by a phone caller did not negate criminal intent, as it did not explain her deliberate acts of breaking into a locked drawer and appropriating specific, valuable items not mentioned by the alleged caller. The defense of frame-up was unsubstantiated. Regarding the penalty, the Court applied Republic Act No. 10951 , which adjusted penalties based on property value. For the stolen amount, the proper penalty is prision mayor in its minimum and medium periods. Applying the Indeterminate Sentence Law, the Supreme Court modified the penalty to an indeterminate sentence of seven (7) years, four (4) months, and one (1) day of prision mayor minimum, to eleven (11) years, six (6) months, and twenty-one (21) days of reclusion temporal medium. The award of P1,189,000.00 as actual damages with legal interest at 6% per annum from finality until full payment was sustained.