Case Digest: JOSEJINA FRIA v. GEMILIANA DE LOS ANGELES

JOSEJINA FRIA v. GEMILIANA DE LOS ANGELES

594 SCRA 530 (2004)

It is essential that the circumstantial evidence presented must constitute an unbroken chain which leads one to a fair and reasonable conclusion pointing to the person being accused, to the exclusion of others, as the guilty person.

Court of Appeals’ stenographer and complainant Josejina Fria charged her co-stenographer, respondent Gemiliana de los Angeles with grave misconduct arising from the loss of money kept in the drawer of Fria’s table in the office. Fria charged de los Angeles on basis of circumstantial matter and prays that she be favored based on such evidence.

ISSUE:

Whether or not the circumstantial evidence is sufficient to declare the de los Angeles guilty

HELD:

Section 4, Rule 133 of the Revised Rules on Evidence provides for the requisites for circumstantial evidence to be considered sufficient, to wit: (a) There is more than one circumstance; (b) The facts from which the inference are derived are proven; and (c) The combination of all the circumstances is such as to prove conviction beyond reasonable doubt.

In the case at bar, Fria established two circumstances viz: prior to the incident, de los Angeles was in dire need of money, and that she was left alone in the office in the late afternoon of December 20, 2001, and was seen alone in the mezzanine between 11:00 a.m. and 12:00 noon of December 21, 2001.

For the third requisite to seal the circumstantial evidence against de los Angeles, it is essential that the circumstantial evidence presented must constitute an unbroken chain which leads one to a fair and reasonable conclusion pointing to the person being accused, to the exclusion of others, as the guilty person.

Though administrative proceedings are not strictly bound by formal rules on evidence, the liberality of procedure in administrative actions is still subject to the limitations imposed by the fundamental requirement of due process, especially if the charge, as in the case at bar, if found to be true, also warrants her indictment criminally.

The circumstances proven by Fria do not completely discount the possibility that, other than de los Angeles, there could be another who could have stolen the money. As testified by Fria herself, the drawer of her table could be opened by a paperclip, the bread knife that lies around in the office, or any key, like that of an officemate’s, that fits. Besides, aside from Fria and de los Angeles, three officemates had a key to the main door. The possibility of others going inside the office at odd hours has not thus been ruled out.