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    Case Digest - Dulnu

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    Graveban Kanashimi

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    Case Digest - Dulnu

    Uploaded by

    Graveban Kanashimi
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    2 views2 pages

    Case Digest - Dulnu

    Uploaded by

    Graveban Kanashimi

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    CASE DIGEST

    Title : Candelaria vs. People

    Case : G.R. No. 209386

    Decision Date : Dec 8, 2014

    Mel Carpizo Candelaria is convicted of Qualified Theft for stealing 14,000 liters of
    diesel fuel worth P497,000.00 from his employer, Viron Transit Corporation, and is
    sentenced to reclusion perpetua without eligibility for parole.

    Facts:

    Case: Candelaria v. People (G.R. No. 209386)

    Date Decided: December 8, 2014

    Court: First Division of the Supreme Court

    Justice: Perlas-Bernabe

    Defendant: Mel Carpizo Candelaria, a truck driver employed by Unioil

    Crime: Convicted of Qualified Theft

    Incident Date: August 23, 2006

    Details:

     Candelaria was tasked to deliver 14,000 liters of diesel fuel worth


    P497,000.00 to Viron Transit Corporation in Laon Laan, Manila.
     By 5 PM, Viron informed Jessielyn Valera Lao, the owner of Unioil, that the
    delivery had not been received.
     Inquiries revealed that Candelaria and his helper, Mario Romano, had left the
    premises at 12:50 PM.
     Lao's attempts to contact Candelaria failed.
     Romano returned alone, reporting that Candelaria had threatened him with a
    balisong.
     The truck was found abandoned and emptied of its diesel fuel in Calamba,
    Laguna.
     Lao filed a complaint for Qualified Theft against Candelaria.
     The RTC of Manila, Branch 21, convicted Candelaria on June 21, 2011.
     Candelaria was sentenced to an indeterminate penalty of fourteen years and
    one day to seventeen years and four months of reclusion temporal and
    ordered to pay indemnity of P497,000.00.
     The Court of Appeals (CA) affirmed the decision on January 31, 2013, but
    modified the indemnity to P14,000.00.
     A motion for reconsideration was denied on September 3, 2013.
    Candelaria filed for review on certiorari before the Supreme Court.

    Issue:

    Primary Issue: Whether the Court of Appeals correctly found Candelaria guilty of
    Qualified Theft based on circumstantial evidence.

    Ruling:

    Supreme Court Decision: The petition was without merit.

    Outcome: Affirmed Candelaria's conviction for Qualified Theft.

    Penalty: Modified to reclusion perpetua without eligibility for parole.

    Indemnity: Ordered Candelaria to indemnify Lao the amount of P497,000.00.

    Ratio:

    Sufficiency of Circumstantial Evidence: The Supreme Court held that circumstantial


    evidence is sufficient for conviction if it meets certain criteria, which were satisfied
    in this case.

    Key Circumstances:

    Candelaria's failure to deliver the diesel fuel.

    His unexplained absence.

    The discovery of the abandoned truck.

    Judicial Notice: The Court took judicial notice of the pump price of diesel fuel in
    August 2006, affirming the stolen property's value at P497,000.00.

    Importance: The decision underscores the necessity for trial courts to thoroughly
    address the value of stolen goods in theft cases for both criminal and civil liability.

    Conclusion: The Supreme Court's ruling ensures that justice is served by upholding
    the conviction and appropriately penalizing the crime committed.

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