Title
Burgundy Realty Corp. vs. Reyes
Case
G.R. No. 181021
Decision Date
Dec 10, 2012
Real estate agent Josefa "Jing" C. Reyes is accused of misappropriating funds entrusted to her by Burgundy Realty Corporation, leading to a legal battle to establish probable cause for estafa charges against her.
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Case Digest (G.R. No. 181021)

Facts:

  • Burgundy Realty Corporation accused Josefa "Jing" C. Reyes of misappropriating PHP 23,423,327.50.
  • The funds were entrusted to Reyes in 1996 to purchase land in Calamba, Laguna, for a golf course.
  • Reyes allegedly used the money for personal purposes instead of buying the land.
  • Despite a formal demand, Reyes did not return the money, leading to a complaint for estafa filed by Burgundy Realty Corporation.
  • Reyes admitted to being a real estate agent but denied misappropriation, claiming the funds were used for their intended purpose.
  • Reyes stated she made down payments to landowners, and the remaining balances were unpaid due to Burgundy Realty Corporation's lack of funds.
  • Reyes mentioned her sub-broker, Mateo Elejorde, deposited the money into his personal account and filed a complaint for estafa against him, leading to his indictment in 2001.
  • The Assistant Prosecutor of Makati City recommended indicting Reyes for estafa under Article 315 of the Revised Penal Code.
  • Reyes sought a review from the DOJ, which initially dismissed her petition but later reconsidered and directed the withdrawal of the information for estafa against her.
  • Burgundy Realty Corporation's petition for certiorari was denied by the Court of Appeals, leading to the present petition for review on certiorari before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted the petition.
  • The Decision and Resolution of the Court of Appeals dated September 14, 2007, and December 20, 2007, respectively, were reversed and set aside.
  • The Regional Trial Court, Branch 149,...(Unlock)

Ratio:

  • The Secretary of Justice has the power of direct control and supervision over prosecutors, including the authority to review their decisions.
  • The purpose of a preliminary investigation is to determine whether a crime has been committed and whether there is probable cause to believe that the accused is guilty.
  • Probable cause does not require proof beyond reasonable doubt but merely a reasonable ground of presumption.
  • The investigating prosecutor correctly found the existence of a...continue reading

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