Case Digest (G.R. No. 156248)
Facts:
Marissa Ceniza-Manantan v. The People of the Philippines, G.R. No. 156248, August 28, 2007, Supreme Court Third Division, Chico‑Nazario, J., writing for the Court. Petitioner Marissa Ceniza‑Manantan (Manantan) was charged with estafa under paragraph 1(b), Article 315 of the Revised Penal Code together with her sister‑in‑law Regina Manantan‑Vizconde; the respondent is the People of the Philippines.On July 15–September 3, 1994, according to the Information, Manantan and Vizconde received several pieces of jewelry worth P1,079,000 from private complainant Alberto Carilla in trust to sell on commission and to remit proceeds or return unsold items; they allegedly failed to do so and misappropriated the property. Carilla filed a criminal complaint; Manantan was arrested on December 2, 1998, arraigned March 5, 1999, and pleaded not guilty. Trial ensued in the Quezon City Regional Trial Court (RTC), Branch 78, where the prosecution presented Carilla as its lone witness and documentary exhibits (complaint‑affidavit, four dishonored checks in Manantan’s name, demand letters). The defense presented Manantan as sole witness, who denied transactions with Carilla and claimed she lent checks to Vizconde.
On July 30, 1999, the RTC convicted Manantan of estafa under Art. 315(1)(b), sentenced her under the Indeterminate Sentence Law, and ordered civil indemnity of P1,079,000. Manantan appealed to the Court of Appeals (CA). On August 29, 2001, the CA affirmed with modification the penalty range (imposing an indeterminate sentence with minimum four years, two months prision correccional and maximum twenty years reclusion temporal). The CA denied reconsideration on November 26, 2002.
Manantan filed a Rule 45 petition for review on certiorari to the Supreme Court. The Court initially denied the petition for procedural defects on March 10, 2003, but reinstated it on May 7, 2003. Petitioner raised principally (1) that the prosecution failed to prove essential elements of estafa (conspiracy and receipt in trust) and that the RTC relied on a single, abbreviated hearing; and (2) that her trial c...(Subscriber-Only)
Issues:
- Was the evidence sufficient to prove beyond reasonable doubt that petitioner committed estafa under Article 315(1)(b) of the Revised Penal Code?
- Did petitioner receive ineffective assistance of counsel at trial such that a new tria...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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