Celedonio v. People GR No.

209137

DOCTRINE: That a person found in possession of a thing taken in the doing of a recent wrongful
act is the taker and the doer of the whole act; otherwise, that things which a person possesses,
or exercises acts of ownership over, are owned by him or her.

FACTS: In April 2007, a robbery of several valuables amounting to Php 223,000 was committed
at the house of one Carmencita De Guzman who was at the time attending the wake of his
deceased husband.

Adriano Marquez who living opposite the victim’s house said that he witnessed the robbery and
that it was Eduardo Celedonio who did it. For this reason, De Guzman reported to the police.
When the police proceeded to go to the accused, they saw him riding a motorcycle, so they
flagged him down. When he was asked where the stolen items she alighted from his motorcycle
and opened its compartment where the officers saw some of the stolen items. The police asked
Celedonio if the same were stolen, to which the latter answered, "Iyan po." Thus, Celedonio
was arrested and was informed of his constitutional rights. More items were seized from
Celedonio at the police station.

During the trial and after the prosecution rested its case, Celedonio filed his Demurrer to
Evidence (with leave of court) citing as his ground the alleged illegality of his arrest and the
illegal search on his motorcycle. The RTC denied the demurrer and eventually convicted him of
the crime of robbery by stating that that the prosecution clearly established that: 1) a robbery
had been committed; 2) it was committed recently; 3) several of the stolen items including cash
were found in Celedonio's possession; and 4) Celedonio had no valid explanation for his
possession of the stolen goods. The CA affirmed the RTC in toto.

ISSUE: Did the CA gravely err in not finding that the search conducted on the petitioner was
illegal, rendering the articles recovered inadmissible?

HELD: NO.

Celedonio was, in fact, caught in exclusive possession of some of the stolen items when the
police officers flagged down his motorcycle during their follow-up operation. He failed to give a
reasonable explanation as to his possession of the said items. Section 3(j), Rule 131 of the
Revised Rules of Court provides that a person found in possession of a thing taken in the doing
of a recent wrongful act is the taker and the doer of the whole act; otherwise, that thing which
a person possesses, or exercises acts of ownership over, is owned by him.

Celedonio never claimed ownership of the subject items. When the alleged stolen items were
found in his motorcycle compartment which he had control over, the disputable presumption
of being the taker of the stolen items arose. He could have overcome the presumption, but he
failed to give a justifiable and logical explanation. Thus, the only plausible scenario that could
be inferred therefrom was that he took the items.
 Cuyugan v. Dizon GR No. L-208

DOCTRINE: The presumption of law against a party who suppresses material evidence shall
apply where a party fails to satisfactorily establish the alleged loss of such material evidence—
that which if produced, may adversely affect his case.

FACTS: In 1940, plaintiff Cuyugan, through a notarized contract, leased to defendant Dizon
several registered parcels of land in Mabalacat, Pampanga which have a combined area of over
33 hectares.

Upon the execution of the contract, the defendant paid the plaintiff P500 and another P500 in
January 1941. Because of the outbreak of war in December 1941, the defendant was only able
to pay P23.50 as rent for the year 1942. The plaintiff made a receipt for this amount, but the
defendant said at the trial that it had been lost. No other rental was ever paid after. As such,
the plaintiff instituted a suit to rescind the lease and to recover the total yearly rental for 1942
and 1943, and for the defendant be condemned to pay the sum of P1,000 as rentals in arrears
for the year 1944.

For his part, defendant averred that the P23.50 he had paid was in full payment of the 1942
rental since, on account of the war, he proposed to the plaintiff and the latter agreed, that he
should pay 100 cavans of palay in lieu of P1,000 in cash. As to the rentals for 1943 and
subsequent years he invoked article 1575 of the Civil Code, which gives the lessee of
agricultural land a right to reduction in case of loss or destruction of more than one-half of the
crops by reason of war or other extraordinary fortuitous events.

ISSUE: Was the defendant correct in her assertions?

HELD: NO.

The trial court believed the plaintiff and we find no occasion to disagree with His Honor. The
alleged loss of the receipt had not been satisfactorily established. The defendant's testimony
that he did not take good care of it because it was not important is unconvincing. As a matter of
fact, the paper was important; and to a lawyer like the defendant its importance could not have
been underestimated, especially if we are to believe his assertion that the receipt cancelled, in
effect, the balance of the rental for 1942, amounting to P767.50. The preservation of the
receipt should have had an added significance to him if we are to accept his other statement
that when he made the payment, he asked the plaintiff for one-half reduction of the rentals for
1943 and subsequent years but that the plaintiff refused to make any commitment. There is
one other factor worth bearing in mind: the basic contract was in a public document and the
defendant, as a lawyer, must have known that to vary its terms he had to have a writing as
proof if not as essential requisite to the validity of the supposed change.

The presumption of law, therefore, against a party who suppresses material evidence is
applicable in this case.