G.R. No. 199907 - Capulong vs. People

The case involves the crime of estafa under Article 315, paragraph 3(c) of the Revised Penal Code.
The offense arose from the concealment of key documents related to a chattel mortgage, namely the Registration Certificate (CR) and the Official Receipt (OR).

On or about December 10, 1990, Anita Capulong and her husband, Fernando Capulong, executed a chattel mortgage over their Isuzu truck by pledging it as security for a loan amounting to ₱700,000.
The documents (OR-CR) were delivered to Francisca P. de Guzman, who is a relative and neighbor, thereby protecting the lender’s (De Guzman’s) interest in the event of default.

Anita later requested to borrow the OR-CR under the pretext of applying for an amendment to the truck’s registration or showing the documents to a prospective buyer.
Despite an initial agreement and issuance of a handwritten receipt as proof of borrowing, Anita allegedly failed to return the OR-CR within the period agreed upon.
Instead, there was evidence suggesting that Anita concealed the borrowed documents and even replaced the truck’s motor, rendering the original OR-CR useless for the purpose of registering or foreclosing the chattel mortgage.

Although the Spouses Capulong pleaded not guilty during arraignment, the trial court convicted Anita of estafa.
The conviction was largely based on the testimony of De Guzman and a document in Anita’s handwriting that confirmed the arrangement for returning the OR-CR.
The trial court emphasized that the failure to return the documents deprived De Guzman of her security, thus causing injury.
Anita was sentenced to an indeterminate prison term of prision mayor (minimum of 6 years and 1 day to 8 years) based on the Indeterminate Sentence Law.

Anita moved for a new trial claiming incompetence and negligence of counsel, and later, introduced a solidbank check as purported new evidence to prove payment of the debt.
Both her motion for a new trial and subsequent motion for reconsideration were denied by the trial court.

On November 12, 2010, the CA affirmed Anita’s conviction but modified the penalty to an indeterminate prison term of four (4) years and two (2) months (prision correccional as minimum) to twenty (20) years (reclusion temporal as maximum).
The CA clarified that the OR-CR, although not emanating from official government offices per se, nonetheless fall within the ambit of documents covered under Article 315, paragraph 3(c) because they are integral to the chattel mortgage.
The appellate court also reversed the joint and several liability clause ordering both spouses to pay ₱700,000, plus interest, thereby deleting that part of the RTC judgment.

Anita’s petition raised multiple issues regarding alleged reversible errors, including questions of law, failure to acquit given the absence of certain estafa elements, and denial of a new trial for lack of due process.
Ultimately, the petition was denied, leaving the CA decision in effect.

Whether the Court of Appeals committed a reversible error by severely limiting the scope of petitionable issues to questions of law under Rule 45 of the Rules of Court.

The petitioner argued that this limitation impeded a full and fair review of both factual and legal errors made by the CA.

Whether the Court of Appeals erred in not acquitting Anita outright despite the apparent absence of the element of prejudice in estafa.

The contention was that without demonstrable prejudice—given that the payment may have been rendered or the loan not directly lost—the essential element of estafa was missing.

Whether the Court of Appeals committed serious error in not acquitting petitioner despite evidence suggesting that the debt had been fully discharged.

This issue centered on whether the existence and subsequent concealment of the OR-CR per se were sufficient to sustain a conviction for estafa in the light of possible reimbursement.

Whether the Court of Appeals abused its discretion by not ordering a remand for a new trial, considering that Anita was allegedly deprived of her day in court due to the repeated absences of counsel and other procedural irregularities.