Theft, Estafa cases; courts must determine the value of the goods involved.

"A final word. Courts dealing with theft, as well as estafa cases, would do well to be mindful of the significance of determining the value of the goods involved, or the amounts embezzled in said cases as they do not only entail the proper resolution of the accused’s civil liability (if the civil aspect has been so integrated) but also delimit the proper penalty to be imposed. These matters, through the trial court’s judicious direction, should be sufficiently passed upon during trial and its finding thereon be amply explained in its verdict. Although an appeal of a criminal case throws the entire case up for review[28], the ends of justice, both in its criminal and civil senses, demand nothing less but complete and thorough adjudication in the judicial system’s every level. Truth be told, the peculiar nature of these cases provides a distinctive opportunity for this ideal to be subserved."

See - 

G.R. No. 209386, December 08, 2014, MEL CARPIZO CANDELARIA, PETITIONER, VS. THE PEOPLE OF THE PHILIPPINES, RESPONDENT.