View full case

HERMAN MEDINA v. PEOPLE

FACTS:

Henry Lim engaged the services of Herman Medina, a mechanic, to repair his jeep. When the jeep was delivered to Medina's shop, no repairs were made despite the lapse of a reasonable time. Lim instructed Danilo Beltran to retrieve the jeep, but Beltran found that the alternator, starter, battery, and two tires with rims worth Php22,500.00 were missing. Medina claimed that he took and installed the missing parts on another vehicle owned by Lim. Beltran eventually retrieved the jeep without the missing parts and had it repaired in his own shop. A criminal complaint was filed against Medina, and he was convicted by the trial court. The conviction was affirmed by the Court of Appeals. Medina filed a petition before the Supreme Court, alleging that the conviction was based only on circumstantial evidence. The prosecution relied on witness testimony while the defense argued that the taking, if any, was with the knowledge and acquiescence of Lim. Medina acknowledged taking the parts but failed to provide supporting documentary evidence. The lower court convicted Medina of theft, and the Court of Appeals affirmed. Medina raised several errors in his petition, including the insufficiency of circumstantial evidence and the failure to consider a receipt marked as an exhibit.

ISSUES:

  1. Whether the missing parts were lawfully taken from the jeep;

  2. Whether the acknowledgment receipt presented by the defense is admissible as evidence.

  3. Whether the denial of the accused can prevail over the positive and categorical testimonies of the prosecution witnesses.

  4. Whether the trial court's assessment of the credibility of the witnesses should be interfered with in the absence of evidence of improper motives.

  5. Whether the factual findings of the trial court, which were affirmed by the Court of Appeals, should be conclusive and binding upon the Supreme Court.

  6. Whether or not the guilt of the accused for the crime of simple theft has been proven beyond reasonable doubt.

  7. Whether or not the penalties imposed on the accused are in accordance with the law.

RULING:

  1. The burden of proof is on the accused to prove that the missing parts were lawfully taken. The accused failed to substantiate his claims that the missing parts were installed in the pick-up owned by another individual and that the owner of the jeep consented to the transfer of the auto parts. The accused did not provide supporting documentary evidence or corroboration for his claims. Thus, the accused failed to prove that the missing parts were lawfully taken.

  2. The acknowledgment receipt presented by the defense is not admissible as evidence because it was not formally offered in court and not incorporated in the case records. Even if it were admitted, it would not exonerate the accused as he himself admitted that the witnesses did not actually see him remove the parts from the jeep and place them in the pick-up.

  3. The denial of the accused cannot prevail over the positive and categorical testimonies of the prosecution witnesses. Denial is considered weak and unreliable, easily fabricated and concocted. To be worthy of consideration, denial should be substantiated by clear and convincing evidence.

  4. In the absence of evidence of improper motives, the trial court's assessment of the credibility of the witnesses shall not be interfered with.

  5. The factual findings of the trial court, affirmed by the Court of Appeals, are generally conclusive and binding upon the Supreme Court. The Supreme Court will only reevaluate the factual findings in exceptional circumstances, such as when the trial court overlooked material and relevant matters or when the factual findings are totally bereft of support in the records or are glaringly erroneous.

  6. The petition is denied. The decision of the Court of Appeals affirming the conviction of the accused is affirmed.

PRINCIPLES:

  • To "take" under the theft provision of the penal code does not require asportation or carrying away. Appropriation means to deprive the lawful owner of the thing.

  • The word "take" includes any act intended to transfer possession, which may be committed through the use of the offender's own hands or any mechanical device.

  • The element of lack of owner's consent is necessary for theft. There can be no theft when the owner voluntarily parts with the possession of the thing.

  • The admission of evidence not formally offered is allowed as long as it has been duly identified by testimony duly recorded and incorporated in the case records.

  • Denial is inherently weak and unreliable and does not prevail over an affirmative assertion of fact.

  • Denial should be substantiated by clear and convincing evidence to be worthy of consideration.

  • The trial court's assessment of the credibility of witnesses shall not be interfered with in the absence of evidence of improper motives.

  • Factual findings of the trial court, affirmed by the Court of Appeals, are generally conclusive and binding upon the Supreme Court, unless there are exceptional circumstances.

  • Proof beyond reasonable doubt is required in criminal cases to secure a conviction.

  • Penalties imposed should be in accordance with the law.