G.R. No. 180016 - Corpuz vs. People

On May 2, 1991 at the Admiral Royale Casino in Olongapo City, private complainant Danilo Tangcoy turned over to petitioner Lito Corpuz jewelry items worth ₱98,000, evidenced by a receipt, on a commission-sale agreement.
They agreed that Corpuz would remit the sale proceeds or return the items within 60 days; Corpuz failed to do either and made unfulfilled payment promises thereafter.

An Information for estafa under Article 315(1)(b) of the Revised Penal Code was filed around July 5, 1991, alleging Corpuz misappropriated the entrusted jewelry.
At trial, the prosecution presented Tangcoy’s testimony and the defense presented Corpuz’s testimony (denying the transaction but admitting a loan receipt). On July 30, 2004, the RTC convicted Corpuz and, under the Indeterminate Sentence Law, imposed imprisonment of 4 years and 2 months (medium prision correccional) to 14 years and 8 months (minimum reclusion temporal), plus indemnity.

The Court of Appeals affirmed conviction but modified the maximum penalty to 8 years of prision mayor plus 1 year for each additional ₱10,000 in excess of ₱22,000 (totaling 15 years maximum).
Corpuz’s motion for reconsideration before the CA was denied (September 5, 2007); he then filed a Rule 45 Petition for Review on Certiorari with the Supreme Court (dated November 5, 2007).

Whether the trial court and CA erred in admitting a photocopied receipt (Exhibit A-1a) in violation of the Best Evidence Rule.

Whether the Information was fatally defective for omitting the 60-day return period and misstating the date (July 5 vs. May 2, 1991).

Whether demand (element of estafa) was proved despite no formal written demand.
Whether inconsistencies in Tangcoy’s testimony and Corpuz’s alternative theory justified acquittal under the equipoise rule.

Whether penalties tied to 1932 peso values result in excessive, outdated sanctions.
Whether courts may judicially adjust such penalties or must leave that to Congress under separation of powers.