Facts:

This case revolves around a criminal complaint for estafa filed by petitioners Oscar Angeles and Emerita Angeles (the "Angeles spouses") against respondent Felino Mercado (Mercado). The complaint originated from a series of events beginning on November 19, 1996, when the Angeles spouses filed their case with the Provincial Prosecution Office in Santa Cruz, Laguna. At the heart of the complaint is a contract of antichresis established in November 1992, wherein Mercado, married to Laura (Emerita’s sister), convinced the Angeles spouses to invest P210,000 for the administration of eight parcels of land in Nagcarlan, Laguna. The parties agreed that the contract would be valid for five years, during which Mercado was tasked with managing the property and facilitating business operations.

After three years, the Angeles spouses requested an accounting from Mercado. He reported earnings in 1993, though he claimed that no fruits were produced in 1994 and notably did not provid

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Facts:

Nature of the Case

• This is a petition for certiorari to annul the letter-resolution dated February 1, 2000, issued by the Secretary of Justice dismissing the complaint for estafa.
• The case challenges the Secretary of Justice’s decision, which was based on an earlier resolution by the Provincial Prosecution Office that had dismissed the complaint.

The Initial Complaint and Alleged Transaction

• On November 19, 1996, the Angeles spouses filed a criminal complaint for estafa under Article 315 of the Revised Penal Code against Felino Mercado before the Provincial Prosecution Office.
• The complaint centers on an alleged contract of antichresis (locally known as sanglaang-perde) covering eight parcels of land in Nagcarlan, Laguna.
• The subject land, planted with lanzones trees and owned by Juana Suazo, was to be administered by Mercado in exchange for a consideration of ₱210,000 over a five-year period.
• The arrangement was made in view of the Angeles spouses residing in Manila and visiting Laguna on weekends, necessitating Mercado’s management and completion of necessary paperwork.

Allegations Regarding the Transaction

• The Angeles spouses assert that in November 1992, Mercado convinced them to enter into the contract despite them not being named in it.
• After three years, when the Angeles spouses demanded an accounting, Mercado provided partial details (e.g., reporting earnings of ₱46,210 for 1993 and stating that no fruits were borne in 1994) but failed to provide accounting for 1995.
• Upon demanding an accounting, they discovered that the contract of antichresis had been executed in the names of Mercado and his spouse, instead of reflecting the Angeles spouses’ name.

Mercado’s Counter-Affidavit and Explanation

• In his counter-affidavit, Mercado denied any misappropriation or deceit.
• He claimed the existence of an industrial or “sosyo industrial” partnership between himself (and his spouse) and the Angeles spouses, which ostensibly had been in effect since 1991, predating the antichresis contract.
• Evidence offered by Mercado included bank receipts showing deposits made on behalf of the Angeles spouses and records from barangay conciliation proceedings held on September 7, 1996.
• During these proceedings, Oscar Angeles acknowledged the existence of a written sosyo industrial agreement whereby the Angeles spouses contributed the capital and profits were to be divided equally with Mercado.

Proceedings Before the Prosecutorial and Executive Branches

• The Provincial Prosecution Office initially issued a resolution on January 3, 1997, recommending the filing of a criminal information for estafa against Mercado, but this was subsequently amended.
• On February 26, 1997, the Prosecutor’s Office issued an amended resolution dismissing the complaint, reasoning that the case was essentially a failed partnership with problems centered on management and accounting rather than estafa.
• A subsequent motion for reconsideration filed by the Angeles spouses was denied in a resolution dated August 4, 1997.
• The Secretary of Justice, after reviewing the records and the evidences presented, dismissed the appeal based on the insufficiency of the allegations to establish deliberate deceit or fraud.

Issue:

Alleged Grave Abuse of Discretion

• Whether the Secretary of Justice committed grave abuse of discretion amounting to lack of jurisdiction in dismissing the appeal of the Angeles spouses.

Existence of a Partnership

• Whether a partnership existed between the Angeles spouses and Mercado, even in the absence of formal documentary proof.

Misappropriation of Proceeds

• Assuming the existence of a partnership, whether Mercado misappropriated proceeds from the lanzones after the Angeles spouses demanded an accounting and Mercado failed to provide one or deliver the proceeds.

Proper Filing of Criminal Charges

• Whether the Secretary of Justice should have ordered the filing of a criminal information for estafa against Mercado.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)