Case Digest (G.R. No. 199907)
Facts:
The case involves Anita Capulong as the petitioner and the People of the Philippines as the respondent, with the decision rendered on February 27, 2017, by the Supreme Court of the Philippines. The events leading to the case began on December 10, 1990, in Cabanatuan City, where Anita Capulong and her husband, Fernando Capulong, were accused of the crime of Estafa. The couple had previously chattel mortgaged their Isuzu truck, with Plate No. PLV-227, for the amount of P700,000.00 in favor of Francisca P. de Guzman. The accusation stemmed from the couple's alleged fraudulent actions when they induced De Guzman to lend them the Registration Certificate and Official Receipt of Payment for the truck under the pretense of applying for an additional loan. Instead of returning the documents, the Capulongs concealed or destroyed them, which prevented De Guzman from registering the chattel mortgage and ultimately led to her inability to foreclose on the truck.
During the trial, ...
Case Digest (G.R. No. 199907)
Facts:
Background of the Case
- Petitioner Anita Capulong and her husband, Fernando Capulong, were accused of Estafa under Article 315, Paragraph 3(c) of the Revised Penal Code (RPC). The case stemmed from a loan transaction involving a chattel mortgage over their Isuzu cargo truck.
Loan and Chattel Mortgage
- On August 7, 1990, the Spouses Capulong borrowed P700,000.00 from private complainant Francisca P. de Guzman, with an agreed interest of 3% per month, payable by June 7, 1991. As security, they executed a Chattel Mortgage with Power of Attorney over their Isuzu truck and delivered the original Official Receipt and Certificate of Registration (OR-CR) to De Guzman.
Alleged Fraudulent Act
- On December 10, 1990, Anita borrowed the OR-CR from De Guzman, claiming she needed it to amend the truck’s registration and show it to a prospective buyer. Anita issued a handwritten receipt for the documents. However, she failed to return the OR-CR despite repeated demands. De Guzman discovered that the truck’s motor had been replaced, making it impossible to register or foreclose the chattel mortgage.
Trial Proceedings
- The Spouses Capulong pleaded not guilty during arraignment. De Guzman testified as the lone prosecution witness, while Anita’s testimony was incomplete due to her counsel’s repeated absence. The trial court convicted Anita of Estafa, sentencing her to imprisonment and holding her jointly and severally liable with Fernando to pay De Guzman P700,000.00 plus 12% interest.
Appeal to the Court of Appeals
- The Court of Appeals (CA) affirmed Anita’s conviction but modified her sentence to an indeterminate prison term of 4 years and 2 months of prision correccional (minimum) to 20 years of reclusion temporal (maximum). The CA also upheld the trial court’s findings that Anita concealed the OR-CR, causing De Guzman to lose the ability to enforce the chattel mortgage.
Issues Raised by Anita
- Whether the CA erred in not acquitting Anita outright due to the absence of prejudice, a required element of Estafa.
- Whether Anita had already paid her obligation, negating the crime of Estafa.
- Whether the case should be remanded for a new trial due to alleged deprivation of her right to due process.
Issue:
- Whether the CA committed reversible error in affirming Anita’s conviction for Estafa under Article 315, Paragraph 3(c) of the RPC.
- Whether the elements of Estafa, particularly prejudice, were sufficiently proven.
- Whether Anita’s alleged payment of her obligation absolves her of criminal liability.
- Whether Anita was deprived of her right to due process, warranting a remand for a new trial.
Ruling:
- The Supreme Court denied Anita’s petition and affirmed the CA’s decision with modification. The Court upheld Anita’s conviction for Estafa but deleted the portion of the trial court’s judgment ordering the Spouses Capulong to jointly and severally pay De Guzman P700,000.00 plus 12% interest.
Ratio:
Elements of Estafa
The crime of Estafa under Article 315, Paragraph 3(c) of the RPC requires:
- The existence of court records, office files, documents, or other papers.
- The offender’s removal, concealment, or destruction of such documents.
- The offender’s intent to defraud another.
The Court ruled that the OR-CR of the Isuzu truck qualified as documents under Article 315, Paragraph 3(c). Their concealment prevented De Guzman from registering the chattel mortgage and foreclosing on the truck, causing her prejudice.
Fraudulent Intent
- Anita’s failure to return the OR-CR, despite her promise to do so, demonstrated her intent to defraud. Her actions made it difficult for De Guzman to enforce the chattel mortgage, forcing her to pursue a collection suit instead of foreclosure proceedings.
Prejudice
- The Court held that the concealment of the OR-CR caused De Guzman to lose the ability to enforce the chattel mortgage, which constituted sufficient prejudice. The extent of the damage was based on the loan amount of P700,000.00, as the OR-CR were indispensable to the mortgage’s enforceability.
Payment of Obligation
- The Court ruled that even if Anita had paid her obligation, it would not extinguish her criminal liability for Estafa. Criminal liability is independent of civil liability, and reimbursement or belated payment does not absolve the accused of the crime.
Due Process
- The Court found that Anita was not deprived of her right to due process. While her counsel’s negligence caused delays, the trial court allowed her to testify, and she was given ample opportunity to present her defense.
Modification of Penalty
- The CA correctly modified Anita’s sentence to an indeterminate prison term of 4 years and 2 months of prision correccional (minimum) to 20 years of reclusion temporal (maximum). However, the Court deleted the trial court’s order for the Spouses Capulong to pay De Guzman P700,000.00 plus interest, as the concealment of documents does not necessarily involve the loss of the loaned amount.
Conclusion:
- The Supreme Court affirmed Anita’s conviction for Estafa under Article 315, Paragraph 3(c) of the RPC. The concealment of the OR-CR caused De Guzman prejudice, and Anita’s intent to defraud was proven beyond reasonable doubt. The Court upheld the modified penalty but removed the civil liability imposed by the trial court.