GR 217680; (May, 2016) (Digest)
G.R. No. 217680 , May 30, 2016
Felix L. Arriola, Petitioner, vs. People of the Philippines, Respondent.
FACTS
Petitioner Felix L. Arriola, a Local Treasury Operations Officer I at the Manila City Hall, and Ma. Theresa Tabuzo (a.k.a. Girlie Moore) were charged with 21 counts of Falsification of Public Document under Article 171 of the Revised Penal Code. The charges stemmed from falsified Community Tax Certificates (CTCs) with Serial Nos. 15492830 to 15492850. In 2002, Gregg Business Agency, through its liaison officer Rosalinda Pagapong, paid Tabuzo to procure CTCs for its clients. Tabuzo delivered the CTCs to Pagapong at the Manila City Hall. When Pagapong presented them at the City Treasurer’s Office for an Order of Payment, they were found to be fake. Verification revealed these serial numbers were part of a batch of 1,000 CTCs (Class A, for unemployed residents, costing P5.00 each) requisitioned and issued to Arriola on January 18, 2002. Tabuzo was identified as a Manila Aide I. The prosecution and defense stipulated that Arriola requisitioned the CTCs on January 18, 2002, and remitted the corresponding triplicate copies on January 21, 2002. Arriola denied knowing Tabuzo or participating in the falsification, claiming he gave the CTC booklets to his subordinates for issuance to taxpayers and merely remitted collections. The Regional Trial Court (RTC) convicted both, finding conspiracy based on circumstantial evidence that Arriola altered the CTCs and Tabuzo acted as courier. The Court of Appeals (CA) affirmed the conviction. Arriola appealed to the Supreme Court.
ISSUE
Whether the prosecution proved the guilt of petitioner Felix L. Arriola for 21 counts of Falsification of Public Document beyond reasonable doubt.
RULING
No. The Supreme Court REVERSED and SET ASIDE the CA Decision and Resolution and the RTC Consolidated Judgment. Petitioner Felix L. Arriola was ACQUITTED for failure of the prosecution to prove his guilt beyond reasonable doubt.
The Court held that the evidence against Arriola was purely circumstantial. The mere fact that he was the accountable officer who requisitioned the CTCs from which the falsified certificates were sourced does not conclusively prove he personally falsified them or conspired with Tabuzo. The prosecution failed to establish an unbroken chain of circumstances leading to the inescapable conclusion that Arriola was the perpetrator. His defense of denial was credible given the lack of direct evidence linking him to the falsified entries. The prosecution did not present evidence that he handled the specific falsified CTCs, prepared them, or received benefits from the scheme. The stipulated facts only proved his official acts of requisition and remittance, not his criminal participation. Conspiracy was not proven as there was no evidence of a common criminal design or agreement between Arriola and Tabuzo. In criminal cases, the burden of proof lies with the prosecution, and any doubt must be resolved in favor of the accused.