### Facts:
– **Initial Incident**: In July 2012, the Bangko Sentral ng Pilipinas (BSP) received information about Romeo Rimando and associates distributing counterfeit US dollar notes. This led to an investigation.
– **Test-Buy and Entrapment Operation**: On September 5, 2012, a test-buy was conducted where BSP agents acquired counterfeit notes from Romeo Rimando. Subsequently, on September 14, an entrapment operation was arranged in Makati, resulting in the arrest of Romeo and Edwina Rimando upon completion of another counterfeit currency transaction.
– **Prosecution’s Evidence**: Highlights included testimonies from BSP officials and a US Secret Service agent identifying the counterfeit nature of the notes. Edwina Rimando and her husband were identified as suppliers.
– **Defense’s Narrative**: Edwina Rimando presented a contradicting story of being in Makati City for a real estate deal regarding old coins. She claimed they were apprehended unexpectedly by BSP agents, suggesting evidence was planted on them.
– **Procedural Posture**: Convictions were handed down by the RTC, and this decision was affirmed by the Court of Appeals (CA). Edwina Rimando filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court, challenging her conviction.
### Issues:
1. **Sufficiency of Evidence**: Whether the evidence presented was sufficient to prove guilt beyond reasonable doubt.
2. **Conspiracy and Participation**: Whether Edwina Rimando’s actions constituted conspiracy and active participation in the commission of the crime.
3. **Admissibility of Evidence**: The challenge regarding the admissibility of the counterfeit notes and the validity of the entrapment operation.
### Court’s Decision:
The Supreme Court settled the case by focusing on key aspects:
– **Re-evaluation of Facts**: While typically the Supreme Court does not re-evaluate evidence, it found it necessary to ensure the protection of constitutional rights.
– **Analysis of Conspiracy**: The Court found the evidence of conspiracy between Edwina and Romeo Rimando lacking. Edwina’s mere presence and passive actions did not convincingly indicate her agreement to commit the crime with her husband.
– **Assessment of Evidence’s Sufficiency**: The Court concluded that Edwina Rimando’s involvement and knowledge of the counterfeit currency operation were not proven beyond reasonable doubt. The prosecution failed to establish her active participation or intent.
– **Final Judgment**: Edwina Rimando was acquitted on the grounds that her guilt was not established beyond reasonable doubt.
### Doctrine:
The Supreme Court underscored the principle that the conviction for conspiracy requires conclusive evidence demonstrating a defendant’s active participation and unequivocal intent to partake in the criminal act. Mere presence or incidental actions without proven concerted intent or action towards committing the crime is insufficient for charging an individual with conspiracy.
### Class Notes:
– **Key Concepts**: Conspiracy, Entrapment Operation, Counterfeit Currency, Evidentiary Sufficiency.
– **Legal Statutes Cited**: Article 168 of the Revised Penal Code on Illegal Possession and Use of Counterfeit Currency.
– **Important Precedents**: The Supreme Court’s decision builds upon the precedent that evidentiary sufficiency, especially in proving conspiracy, must be beyond reasonable doubt, affirming the high standard required for criminal convictions in the Philippines.
### Historical Background:
This case underscores the vigilant efforts of the Philippine authorities, particularly the BSP, in combating the circulation of counterfeit currency, showcasing the legal challenges in proving conspiracy without direct evidence of an individual’s participatory intent or action.
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