Crimpro 41-50

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People v. Mateo, G.R. Nos.

147678-87, 7 July 2004

Facts
The case involves accused-appellant Ervin Y. Mateo, who appealed the
decision of the Court of Appeals (CA) affirming his conviction for syndicated
estafa. The case originated from the Regional Trial Court (RTC) of Makati
City, where Mateo was found guilty of syndicated estafa and sentenced to
life imprisonment for each count. In March 2001, private complainant
Herminio Alcid, Jr. met Geraldine Alejandro, who introduced herself as the
head of the Business Center of MMG International Holdings Co., Ltd.
Geraldine solicited investments and showed a brochure and Articles of
Partnership to prove that MMG is a registered entity. Herminio, Jr. invested
P50,000.00 with MMG, and later, he and his father made a joint investment
of P200,000.00. The investments were covered by a notarized Memorandum
of Agreement (MOA) signed by accused-appellant. However, when the
complainants tried to deposit the post-dated checks they received, they
were informed that MMG's accounts were closed. The complainants
demanded the return of their money, but their demands were ignored. They
then filed a complaint with the Securities and Exchange Commission (SEC),
which forwarded the complaint to the City Prosecutor of Makati. Accused-
appellant, together with other individuals, was charged with syndicated
estafa.

Issue
The main issue raised in the case is whether accused-appellant can be
convicted of estafa under Article 315, paragraph 2(a) of the Revised Penal
Code (RPC) in relation to Presidential Decree No. 1689 (PD 1689). Accused-
appellant argues that PD 1689 only contemplates estafa under Article 315,
paragraph 1(b) of the RPC.

Ruling
The court ruled that accused-appellant can be found guilty of violating PD
1689 in relation to estafa under Article 315, paragraph 2(a) of the RPC. The
court explains that estafa under Article 315, paragraph 2(a) involves
defrauding another by means of false pretenses or fraudulent acts executed
prior to or simultaneously with the commission of the fraud. PD 1689, on the
other hand, punishes syndicated estafa, which involves a large-scale
swindling activity perpetrated by a syndicate. The court held that the
elements of syndicated estafa were present in this case, as there was a
conspiracy among the accused to defraud the complainants. The court also
found that the accused-appellant was a partner in MMG International
Holdings Co., Ltd., and actively participated in the fraudulent acts committed
by the partnership. Therefore, the court affirmed the conviction of accused-
appellant for syndicated estafa.

Antone v. People G.R. No. 225146, 20 November 2017

Facts
The case involves the conviction of Rogelio B. Antone for two counts of
statutory rape. The charges were filed before the Regional Trial Court (RTC)
of Guihulngan, Negros Oriental, alleging that Antone raped his 11-year-old
niece-in-law, AAA, on two separate occasions in 1997. AAA testified that
Antone forcibly had sexual intercourse with her, threatened to kill her if she
told anyone, and engaged in similar acts multiple times. AAA eventually
admitted to her mother about the sexual encounters with Antone after
engaging in an incestuous relationship with her own brother. AAA's parents
had her medically examined and filed criminal charges against Antone.
Antone, in his defense, denied the charges and claimed that AAA and her
brother were caught engaging in incestuous relations, and that AAA's
parents falsely accused him to cover up the family embarrassment.

Issue
The main issue before the Court is whether or not Antone's conviction should
be upheld.

Ruling
The Court dismissed the petition, noting that Antone made a procedural
lapse by filing a petition for review on certiorari under Rule 45 of the Rules
of Court instead of filing a notice of appeal before the Court of Appeals (CA).
As a result, the CA's decision and resolution have already become final and
immutable. The Court emphasized that a decision that has acquired finality
may no longer be modified, except in certain exceptional circumstances that
do not apply in this case. Therefore, Antone's conviction remains.

Batistis v. People G.R. No. 181571, 16 December 2019

Facts:
Juno Batistis was convicted by the Regional Trial Court (RTC) for violations
of Section 155 (infringement of trademark) and Section 168 (unfair
competition) of the Intellectual Property Code. The Court of Appeals (CA)
affirmed the conviction for infringement of trademark but reversed the
conviction for unfair competition. Batistis appealed to the Supreme Court to
challenge the CA's affirmance of his conviction for infringement of
trademark. The case stemmed from a test-buy conducted by agents of the
National Bureau of Investigation (NBI) in Batistis' premises, which confirmed
that he was engaged in the manufacture, sale, and distribution of counterfeit
Fundador brandy products. A search warrant was issued, and various
counterfeit items were found in Batistis' possession.

Issue:
Whether the RTC erred in convicting Batistis based on the self-serving
affidavits and testimonies of the police officers who conducted the raid on his
house.

Ruling:
The Supreme Court affirms the conviction but modifies the penalty by
imposing an indeterminate sentence. The appeal is dismissed because it
raises factual and evidentiary issues, which are not within the scope of a
petition for review on certiorari. The Court also upholds the factual findings
of the RTC and CA, as they correctly appreciated the evidence against
Batistis and applied the relevant law. Batistis' acts constituted infringement
of trademark under Section 155 of the Intellectual Property Code. The
penalty imposed by the RTC, however, was contrary to the Indeterminate
Sentence Law. The Court modifies the penalty to comply with the
Indeterminate Sentence Law.

People v. Sandiganbayan (Fourth Division), G.R. No. 228281, June 14, 2021
Facts:
This case involves the Contract for the Supply of Equipment and Service for
the National Broadband Network Project (NBN Project) between the
Government of the Republic of the Philippines and Zhing Xing
Telecommunications Equipment, Inc. (ZTE), a Chinese corporation. Benjamin
S. Abalos, the Chairman of the Commission on Elections (COMELEC) at the
time, was charged with violation of Section 3 (h) of Republic Act (R.A.) No.
3019, or the Anti-Graft and Corrupt Practices Act. The charge alleged that
Abalos had financial or pecuniary interest in the business transaction
between the Philippine Government and ZTE for the implementation of the
NBN Project, despite being prohibited from doing so by the Constitution.

Issue:
The main issue in this case is whether Abalos is guilty of violation of Section
3 (h) of R.A. No. 3019.

Ruling:
The Sandiganbayan Fourth Division acquitted Abalos of the charge for failure
of the prosecution to establish his guilt beyond reasonable doubt.

Cu v. Small Business Guarantee and Finance Corporation G.R. No. 211222, 7


August 2017

Facts:
This case involves a dispute between Small Business Guarantee and Finance
Corporation (SBGFC) and Allan S. Cu, Norma B. Cueto, and Lucia C. Pascual
(petitioners). SBGFC, a government financial institution, entered into a credit
line agreement with Golden 7 Bank (G7 Bank) for a loan amount of
P90,000,000.00. The petitioners, as officers of G7 Bank, issued several
postdated checks in payment for the loan, but the checks were dishonored
due to "Account Closed."

Meanwhile, G7 Bank was placed under receivership by the Bangko Sentral


ng Pilipinas (BSP) and its assets and affairs were placed under the Philippine
Deposit Insurance Corporation (PDIC) as receiver. SBGFC filed complaints
for violation of Batas Pambansa Bilang 22 (B.P. 22) against the responsible
officers of G7 Bank. The Metropolitan Trial Court of Makati City (MeTC Makati
City) dismissed the case, ruling that it was impossible for G7 Bank to fund
the checks after being placed under receivership. The Regional Trial Court
(RTC) Makati City affirmed the dismissal.

SBGFC appealed to the Court of Appeals (CA), arguing that the officers of G7
Bank can still be held criminally and civilly liable for the dishonored checks.
The CA initially dismissed the appeal, stating that only the Office of the
Solicitor General (OSG) can represent the People in criminal appeals.
However, the CA later reconsidered its decision and granted SBGFC's petition
for review. The CA held that the criminal aspect of the case should not be
affected by the receivership of G7 Bank, as it would allow individuals
engaged in criminal conduct to escape liability by filing for rehabilitation. The
CA ordered the reinstatement of the criminal cases.

The petitioners filed a petition for review on certiorari with the Supreme
Court, arguing that the CA erred in reinstating the criminal cases against
them.
Issue:
Whether the officers of G7 Bank can be held criminally liable for violation of
B.P. 22 for the dishonored checks.

Ruling:
The Supreme Court ruled that the officers of G7 Bank cannot be held
criminally liable for the bounced checks. The closure of G7 Bank by the
Monetary Board and the subsequent takeover by the Philippine Deposit
Insurance Corporation (PDIC) suspended the obligation to pay the amounts
covered by the dishonored checks. Therefore, the officers of G7 Bank cannot
be held criminally liable for the bounced checks.

People v. Libre G.R. No. 235980, 20 August 2018

Facts
This case involves the appeal of accused-appellant Leonila Pueblas Libre,
also known as "Inday Nilay," against her conviction for violating Section 5,
Article II of Republic Act No. 9165 or the Comprehensive Dangerous Drugs
Act of 2002. The case originated from an information filed before the
Regional Trial Court (RTC) charging Leonila and her co-accused, Joseph
Pontijos Libre, also known as "Joyjoy," with illegal sale of dangerous drugs.

The prosecution alleged that on June 5, 2012, the Regional Anti-Illegal Drug
Special Operations Task Group 7 received a report that Leonila and Joseph
were engaged in selling shabu in Cebu City. Acting on the report, the police
conducted a buy-bust operation, during which Leonila and Joseph were
arrested. The police seized a plastic sachet containing suspected shabu from
Joseph and recovered the marked money from Leonila. The seized sachet
was later tested positive for methamphetamine hydrochloride.

The RTC found Leonila and Joseph guilty beyond reasonable doubt and
sentenced them to life imprisonment and a fine of P500,000 each. The RTC
ruled that the prosecution successfully established all the elements of the
crime and that the presumption of regularity in the performance of official
function prevailed over the accused's mere denials.

Issue
The main issue before the Supreme Court is whether or not the conviction of
the accused was proper based on the evidence presented and the
compliance with the procedures set forth in Republic Act No. 9165.
Ruling
The Supreme Court ruled in favor of the accused and acquitted them of the
crime charged. The Court emphasized the importance of strict compliance
with the procedures set forth in Section 21 of Republic Act No. 9165 in order
to ensure the integrity and evidentiary value of the seized drugs. The Court
held that any deviation from the prescribed procedure must be justified by
the prosecution, and failure to do so would result in the acquittal of the
accused.

Usares v. People G.R. No. 209047, 7 January 2019

Facts
This case involves a petition for review on certiorari filed by Angela Usares y
Sibay (Usares) against the People of the Philippines. The case was brought
before the Second Division of the Supreme Court of the Philippines.

In a decision dated February 23, 2012, the Regional Trial Court (RTC) found
Usares guilty of the crime of Homicide and sentenced her to imprisonment
for a period of eight to twelve years. The RTC also ordered her to pay
damages to the heirs of the victim. Usares filed a Notice of Appeal on April
12, 2012, which was granted by the RTC on May 10, 2012.

However, on November 28, 2012, a motion for the issuance of a warrant of


arrest was filed against Usares. The Court of Appeals (CA) dismissed
Usares's appeal and referred the motion for the issuance of a warrant of
arrest to the RTC for appropriate action. The CA held that Usares had
jumped bail and therefore forfeited her right to pursue an appeal. Usares
filed a motion for reconsideration, which was denied by the CA. Aggrieved,
Usares filed a petition for review on certiorari before the Supreme Court.

Issue
The main issue before the Court was whether or not the CA was correct in
dismissing Usares's appeal.

Ruling
The Supreme Court ruled in favor of Usares and granted her petition for
review on certiorari. The Court set aside the decision of the CA and
reinstated Usares's appeal before the RTC.
Sy Tan v. Sy Tiong Gue, G.R. No. 174570, 15 December 2010

Facts:
Romer Sy Tan filed a petition against Sy Tiong Gue, Felicidad Chan Sy, Sy
Chim, Sy Tiong San, Sy Yu Bun, Sy Yu Shiong, Sy Yu San, and Bryan Sy
Lim. The Court of Appeals previously issued a decision and resolution in
favor of the respondents, but the Supreme Court reversed and set aside this
decision in a ruling dated December 29, 2005. The Supreme Court reinstated
the orders of the Regional Trial Court (RTC) dated September 1, 2003, and
October 28, 2003, which upheld the validity of search warrants issued
against the respondents.

Issue:
The main issue raised in this case is whether or not the withdrawal of the
information filed in Criminal Case No. 06-241375 renders the quashal of the
search warrants moot and academic.

Ruling:
The Supreme Court granted the motion for reconsideration filed by the
respondents and reconsidered and set aside its previous decision. The
petition filed by Romer Sy Tan was denied for being moot and academic.

Vaporoso v. People, G.R. No. 238659, June 3, 2019

Facts:
The case involves petitioners Franklin B. Vaporoso and Joelren B. Tulilik who
were charged with illegal possession of dangerous drugs under Section 11,
Article II of Republic Act No. 9165 or the Comprehensive Dangerous Drugs
Act of 2002. The Information against Vaporoso and Tulilik was filed on
August 27, 2013. The police officers conducted a buy-bust operation and
arrested the petitioners. During the arrest, the police officers conducted a
cursory body search on the petitioners but did not find any drugs. However,
a subsequent search conducted at the Panabo Police Station yielded drugs.
The Regional Trial Court (RTC) convicted the petitioners, but the Court of
Appeals (CA) reversed the decision of the RTC.

Issue:
The main issue in this case is whether the subsequent search conducted at
the Panabo Police Station, which yielded drugs, is lawful and admissible as
evidence.

Ruling:
The Supreme Court granted the petition and reversed the decision of the
Court of Appeals. The subsequent search conducted at the Panabo Police
Station is deemed unlawful and unreasonable. As a result, the drugs
recovered from the second search are considered inadmissible evidence. The
petitioners are acquitted and exonerated from criminal liability.

People v. Cogaed, G.R. No. 200334, 30 July 2014

Facts
The case involves the arrest and search of Victor Cogaed, who was a
passenger carrying a bag while traveling aboard a jeepney. The jeepney
driver signaled to the police that Cogaed was "suspicious." The police officers
approached Cogaed and asked him to open his bag, where they found illegal
drugs. Cogaed was then arrested and charged with drug possession.

Issue
The main issue in the case is whether the search and seizure of Cogaed's
bag was valid, considering that it was based solely on the suspicion of the
jeepney driver and without any other suspicious circumstances.

Ruling
The Supreme Court ruled that the search and seizure of Cogaed's bag was
illegal. The court held that the police officers cannot rely solely on the
suspicion of another person, in this case, the jeepney driver, to justify a
search. The police officers should have observed facts that would lead to a
reasonable degree of suspicion themselves. Since there were no suspicious
circumstances observed by the police officers, the search was deemed
unconstitutional.

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