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LEONILA BATULANON v. PEOPLE

This case has been cited 3 times or more.

	GR No. 215424 2015-12-09	ADINA B. MANANSALA v. PEOPLE PERLAS-BERNABE, J.
The elements of Falsification of Private Documents under Article 172 (2) of the RPC are: (a) that the offender committed any of the acts of falsification, except those in Article 171 (7) of the same Code; (b) that the falsification was committed in any private document; and (c) that the falsification caused damage to a third party or at least the falsification was committed with intent to cause such damage.[25] On the other hand the elements of Falsification under Article 171 (4) of the RPC are as follows: (a) the offender makes in a public document untruthful statements in a narration of facts; (b) he has a legal obligation to disclose the truth of the facts narrated by him; and (c) the facts narrated by him are absolutely false.[26]
	GR No. 206162 2014-12-10	ALEX M. VALENCERINA v. PEOPLE MENDOZA, J.
In all criminal cases, the prosecution is burdened with the duty of establishing with proof beyond reasonable doubt the guilt of an accused.[12] The determination of whether the prosecution has fulfilled such a heavy burden is left to the trial court, which, in turn, must be satisfied with moral certainty that an accused has indeed committed the crime on the basis of facts and circumstances to warrant a judgment of conviction.[13] Otherwise, where there is reasonable doubt, acquittal must then follow.[14] The premise is that an accused is presumed innocent until the contrary is proved.[15]
	GR No. 152065 2008-01-29	BELEN REAL v. PEOPLE AZCUNA, J.
Although the trial court only mentioned in passing that damage was caused to private complainant Uy, it cannot be denied that there exists a factual basis for holding that petitioner's refusal to account for or return the pieces of jewelry had prejudiced the rights and interests of Uy. Certainly, disturbance of property rights is equivalent to damage and is in itself sufficient to constitute injury within the meaning of Art. 315, par. 1 (b) of the RPC.[12] In this case, Uy, who is a businessman, not only failed to recover his investment but also lost the opportunity to realize profits therefrom. Anxiety also set in as he ran the risk of being sued by the person who likewise entrusted him the same pieces of jewelry. To assert his legal recourse, Uy further incurred expenses in hiring a lawyer and in litigating the case.