GR 209386; (December, 2014) (Digest)
G.R. No. 209386, December 8, 2014
Mel Carpizo Candelaria, Petitioner, vs. The People of the Philippines, Respondent.
FACTS
Petitioner Mel Carpizo Candelaria was a truck driver employed by Jessielyn Valera Lao, owner of United Oil Petroleum Phils. (Unioil). On August 23, 2006, he was dispatched to deliver 14,000 liters of diesel fuel worth ₱497,000.00 to Viron Transit Corporation in Manila. Viron later informed Lao that the order was not received. Lao discovered that Candelaria, with his helper Mario Romano, left the company premises with the loaded truck but failed to make the delivery. Candelaria did not respond to Lao’s phone calls. Romano later returned alone and reported that Candelaria had poked a balisong at him. The truck was later found abandoned and empty in Calamba, Laguna. Lao filed a complaint for Qualified Theft. The Regional Trial Court convicted Candelaria, a ruling affirmed by the Court of Appeals, which modified the indemnity to ₱14,000.00 due to lack of supporting documents for the claimed value.
ISSUE
Whether the Court of Appeals correctly found Candelaria guilty of Qualified Theft on the basis of circumstantial evidence.
RULING
Yes, the Court of Appeals correctly affirmed the conviction. The Supreme Court held that all elements of Qualified Theft were present: (a) taking of personal property; (b) property belonging to another; (c) intent to gain; (d) without the owner’s consent; (e) without violence or intimidation; and (f) with grave abuse of confidence as a domestic servant. The conviction, based on circumstantial evidence, was proper as the circumstances formed an unbroken chain leading to the reasonable conclusion of Candelaria’s guilt. These circumstances included: Candelaria was tasked with the delivery; he left with the loaded truck; the delivery was not made; he did not respond to calls; the truck was found empty; and he never reported back to work. His unexplained flight and failure to account for the goods further indicated guilt. The Court sustained the penalty but, citing jurisprudence on proving value, found the evidence insufficient to support the ₱497,000.00 valuation. However, it took judicial notice of the prevailing price of diesel and determined the value to be at least ₱526,400.00 (14,000 liters at ₱37.60 per liter), warranting the penalty imposed. The petition was denied.