G.R. No. 206437 November 22, 2017
LEANDRO CRUZ, EMMANUEL MANAHAN, ALRIC JERVOSO, Petitioners vs. PEOPLE OF THE PHILIPPINES, Respondent

FACTS

Petitioners Leandro Cruz, Emmanuel Manahan, and Alric Jervoso were employees of Prestige Brands Phils., Inc., holding positions as Warehouse Supervisor, Assistant Warehouse Supervisor, and Delivery Driver cum Warehouse Assistant, respectively. They, along with another accused who remained at large, were charged with Qualified Theft for the alleged unlawful taking of company products valued at approximately Php 1.12 million in October 2003. The prosecution alleged that, by virtue of their positions, petitioners enjoyed the trust and confidence of the company, having exclusive access to the warehouse. The discovery of the loss stemmed from inventory discrepancies. The prosecution presented written confessions allegedly executed by Cruz and Jervoso, and testimonies that Cruz, Jervoso, and their co-accused admitted the theft to the company president.
The defense denied the accusations. Petitioners claimed the confessions were coerced, extracted under duress from the company president who threatened to involve their families and media exposure. They argued that the warehouse had a two-door system with separate locks, and that only the Vice-President held a key to the inner door, making unauthorized removal difficult. They also contended that non-warehouse personnel were frisked upon exit, while they, as authorized personnel, were not, suggesting the loss could have been caused by others.

ISSUE

Whether the guilt of the petitioners for the crime of Qualified Theft was proven beyond reasonable doubt.

RULING

No. The Supreme Court acquitted the petitioners. The Court emphasized that in criminal cases, the burden of proof lies with the prosecution, and guilt must be established beyond reasonable doubt. For Qualified Theft, the prosecution must prove the taking of personal property, intent to gain, absence of consent, and that it was committed with grave abuse of confidence. The Court found the evidence insufficient to meet this stringent standard.
The purported confessions were deemed unreliable. The circumstances under which they were obtained—alleged threats and promises of no criminal complaint—cast serious doubt on their voluntariness, rendering them inadmissible. Furthermore, the prosecution failed to present the original copies of these documents or satisfactorily explain their absence, violating the best evidence rule. The inventory reports purportedly showing the loss were also not formally offered as evidence. Crucially, the element of “taking” was not conclusively established. The defense successfully raised reasonable doubt by highlighting the warehouse’s security protocols, which included multiple locks not all accessible to petitioners, and the possibility that other individuals with access could have been responsible for the missing items. The totality of the evidence created an equipoise, which must be resolved in favor of the accused.