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ENGR. ANT V. ZAPANTA v. PEOPLE

FACTS:

Engr. Anthony V. Zapanta filed a petition challenging the decision of the Court of Appeals (CA) affirming his conviction for qualified theft. The case stemmed from an Information filed with the Regional Trial Court (RTC) charging Zapanta and Concordia O. Loyao, Jr. with qualified theft. The information alleged that Zapanta, as the project manager of the Porta Vaga Building Construction, conspired with Loyao to steal wide flange steel beams from the project site without the knowledge and consent of the owner, ANMAR, Inc. Zapanta pleaded not guilty during his arraignment, while Loyao remained at-large.

During the trial, the prosecution presented oral testimonies and documentary evidence to prove their case. The evidence showed that Zapanta instructed a truck driver and several Anmar welders to unload steel beams at a different project site in October and November 2001. Later on, it was discovered that the steel beams were missing and had not been properly accounted for. An inventory of the construction materials was conducted, and it was found that the stolen steel beams amounted to P2,269,731.69.

Zapanta vehemently denied the charges and claimed that he was wrongfully accused by Engr. Lorna Marigondon, the general manager of ANMAR, Inc., who he alleged had a personal motive for accusing him.

The RTC ultimately convicted Zapanta of qualified theft based on the prosecution's evidence and sentenced him to imprisonment and indemnification of ANMAR, Inc. with legal interest, as well as the payment of moral damages to Engr. Marigondon. The CA affirmed the RTC's decision but deleted the award of moral damages.

Zapanta filed a petition for review on certiorari before the Supreme Court, arguing that he was convicted for acts not covered by the information and that the prosecution failed to establish the fact of the loss of the steel beams.

The issue before the Supreme Court was whether the CA committed a reversible error in affirming Zapanta's conviction for qualified theft.

ISSUES:

  1. Whether the CA committed a reversible error in affirming the RTC's decision convicting the petitioner of the crime of qualified theft.

  2. Whether the alleged stolen beams or corpus delicti were sufficiently established by the prosecution.

RULING:

  1. The petition lacks merit. The Supreme Court affirmed the conviction for qualified theft, finding that the essential elements of the crime were proven beyond reasonable doubt. The Court ruled that the information need not state the precise date of the offense, as the date is not a material element of the crime.

  2. Corpus delicti was established. The Supreme Court ruled that the corpus delicti or the fact of the commission of the crime was sufficiently established through testimonial and documentary evidence, corroborating the prosecution's claims that the petitioner directed the unloading of stolen steel beams.

PRINCIPLES:

  • Sufficiency of Complaint or Information: A complaint or information is sufficient if it states the approximate date of the commission of the offense, even if not precise, as long as the date is not a material ingredient of the offense.

  • Corpus Delicti: Corpus delicti refers to the fact of the commission of the crime. In theft, it has two elements: (1) the owner lost the property, and (2) the property was lost through felonious taking.

  • Legal Terminology in Penalties: Courts must employ the proper legal terminology in the imposition of penalties due to their substantial differences in legal effects and accessory penalties.

  • Penalty for Qualified Theft: For qualified theft, the penalty is two degrees higher than for simple theft per Article 310 of the Revised Penal Code, thus reclusion perpetua applies if the stolen amount exceeds the threshold specified in Article 309.