Case Digest (G.R. No. L-50581-50617)
Facts:
Capulong v. People, G.R. No. 199907, February 27, 2017, Supreme Court Second Division, Peralta, J., writing for the Court. Petitioner Anita Capulong was criminally charged, together with her husband Fernando (the Spouses Capulong), in an Information filed February 28, 1995 for estafa under Article 315, paragraph 3(c) of the Revised Penal Code for allegedly inducing Francisca P. de Guzman to lend back the OR-CR (Official Receipt–Certificate of Registration) of an Isuzu truck that had been delivered as security for a P700,000 loan, and thereafter concealing or destroying those documents and replacing the truck engine so the chattel mortgage could not be registered or foreclosed.At arraignment the Spouses Capulong pleaded not guilty. Trial proceeded with De Guzman as the lone prosecution witness; she testified about the P700,000 loan, the promissory note, the chattel mortgage and surrender of the truck’s OR-CR, and that Anita borrowed the OR-CR on December 10, 1990 and did not return them despite demands. Anita admitted receipt of the loan, execution of the chattel mortgage and borrowing the OR-CR, but claimed she returned them a week later and disputed some entries on the handwritten receipt. Defense testimony was not completed and Anita was not cross‑examined due to repeated absences of counsel; the trial court ultimately considered the case submitted on the record.
On August 1, 2003, the Regional Trial Court (RTC), Branch 86, Cabanatuan City, convicted Anita alone of estafa under Art. 315(3)(c), sentenced her to prision mayor in its minimum period, and ordered the Spouses Capulong jointly and severally to pay De Guzman P700,000 plus 12% interest. Anita moved for a new trial alleging counsel incompetence and later claimed discovery of Solidbank Check No. PA074896 (Sept. 8, 1992) as newly discovered evidence; the trial court denied the motions (Feb. 26, 2004; May 17, 2004) holding the check was not newly discovered and was available to the defense. Notice of Appeal followed.
On November 12, 2010, the Court of Appeals (CA) in CA‑G.R. CR No. 28713 affirmed the RTC conviction but modified the penalty to an indeterminate term of prision correccional (minimum: 4 years, 2 months) to reclusion temporal (maximum: 20 years), and affirmed denial of new trial. Anita’s motion for reconsideration before the CA was denied in a December 22, 2011 Resolution. She filed a petiti...(Pro-only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion or reversible error warranting relaxation of Rule 45’s restriction to questions of law?
- Whether the elements of estafa under Article 315, paragraph 3(c) RPC—particularly prejudice or injury—were not established because the OR-CR are not documents evidencing indebtedness.
- Whether Anita’s alleged subsequent payment (Solidbank check) extinguished criminal liability or whether the check qualified as newly discovered evidence warranting acquittal or new trial.
- Whether Anita was deprived of her constitutional right ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)