Title
Burgos, Jr. vs. Spouses Naval
Case
G.R. No. 219468
Decision Date
Jun 8, 2016
Burgos alleged fraud in property transfer via falsified documents; criminal case dismissed due to prescription, but civil action for damages remains viable.
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Case Digest (G.R. No. 219468)

Facts:

Ownership and Mortgage of the Property
Jose Burgos, Jr. (Burgos) and his wife, Rubie S. Garcia-Burgos, were the registered owners of a 1,389-square-meter lot in Taytay, Rizal, covered by Transfer Certificate of Title (TCT) No. 550579. On November 19, 1996, the property was mortgaged to Antonio Assad. To avoid foreclosure, Burgos sought a loan from spouses Eladio and Arlina Naval (Sps. Naval) and their daughter, Amalia Naval (collectively, respondents). In return, Burgos and his wife signed blank documents, which they later discovered were used to transfer ownership of the property to Sps. Naval.

Discovery of Fraud
In February 2011, Burgos discovered that TCT No. 550579 had been canceled, and a new title, TCT No. 644582, was issued in favor of Sps. Naval on April 1, 1998. The blank documents signed by Burgos and his wife were allegedly used to create a receipt and a Deed of Absolute Sale, transferring ownership of the property to Sps. Naval.

Criminal Complaint
On April 26, 2012, Burgos filed a letter-complaint with the Office of the Provincial Prosecutor, Taytay, Rizal, charging respondents with Estafa through Falsification of Public Documents. An Information was filed on February 11, 2013, before the Regional Trial Court (RTC) of Antipolo City, docketed as Criminal Case No. 13-45768.

Motion to Quash
Before arraignment, respondents filed a motion to quash, arguing that:

  1. The criminal liability had prescribed, as the alleged crime occurred on April 1, 1998, and the Information was filed on February 11, 2013, beyond the 10-year prescriptive period.
  2. The Information failed to charge Amalia with an offense.
  3. Respondents were not afforded the opportunity for a preliminary investigation.

RTC Ruling
The RTC granted the motion to quash on August 14, 2013, dismissing the case on the ground of prescription. The court ruled that the prescriptive period began on April 1, 1998, when the falsified documents were registered, and more than 10 years had elapsed by the time the Information was filed. Burgos's motion for reconsideration was denied on July 14, 2014.

Appeal to the Court of Appeals (CA)
Burgos filed a petition for certiorari with the CA, docketed as CA-G.R. SP No. 138203. The CA dismissed the petition on March 5, 2015, for Burgos's failure to join the People of the Philippines, represented by the Office of the Solicitor General (OSG), as required by law. Burgos's motion for reconsideration was denied on July 2, 2015.

Issue:

  1. Whether the CA correctly dismissed Burgos's certiorari petition for failure to implead the People, represented by the OSG, as a party.
  2. Whether the crime of Estafa through Falsification of Public Documents had prescribed.

Ruling:

The Supreme Court denied Burgos's petition, affirming the CA's dismissal of his certiorari petition. The Court held that:

  1. The OSG, as the legal representative of the People, must authorize any appeal or certiorari petition involving the criminal aspect of a case. Burgos failed to secure such authorization.
  2. The CA correctly dismissed the petition for Burgos's failure to implead the People, represented by the OSG, as a party.
  3. The dismissal of the criminal case on the ground of prescription does not extinguish Burgos's right to pursue a civil action for damages under Rule 111 of the Rules of Criminal Procedure.

Ratio:

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