Title
Debuque vs. Nilson
Case
G.R. No. 191718
Decision Date
May 10, 2021
The Supreme Court dismissed the Syndicated Estafa complaint against Ramon H. Debuque and others due to Debuque's acquittal and the death of the principal accused, eliminating any legal basis to continue.
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Case Digest (G.R. No. 191718)

Facts:

  • The case "Debuque v. Nilson" involves a complaint for Syndicated Estafa filed by Matt C. Nilson against Ramon H. Debuque and others.
  • Initially filed before the Office of the City Prosecutor of Quezon City, docketed as I.S. No. 05-5856.
  • Nilson, the Managing Director of Tongsat in the early 1990s, met Atty. Ignacio D. Debuque, Jr., Chairman of Domestic Satellite Philippines, Inc. (DOMSAT).
  • They developed a professional relationship, and Atty. Debuque borrowed substantial funds from Nilson multiple times.
  • Atty. Debuque invited Nilson to join a business venture, promising shares of stock in Investa Land Corporation (ILC) equivalent to the value of the loans.
  • Nilson contributed funds for the purchase of commercial lots and operational funds for ILC.
  • Nilson claimed the lots were misrepresented, and the promised shares were never issued.
  • Nilson filed a complaint for Syndicated Estafa against Atty. Debuque, Ramon, and others.
  • The City Prosecutor found probable cause for Syndicated Estafa, but the DOJ Secretary reversed this finding, limiting the charge to Estafa against Atty. Debuque alone.
  • The case was elevated to the Court of Appeals (CA), which reinstated the City Prosecutor's finding of probable cause for Syndicated Estafa against all accused.
  • Ramon filed a Petition for Review on Certiorari before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court dismissed the Petition for Review on Certiorari on grounds of mootness.
  • The dismissal was based on the Regional Trial Court's (RTC) dismissal of the case against Ramon H. Debuque due to a demurrer to evidence, effectively amounting to an acqui...(Unlock)

Ratio:

  • The Supreme Court found the case moot and academic due to the RTC's dismissal of the criminal case against Ramon, Margarita, and Luz based on a demurrer to evidence, resulting in their acquittal.
  • The RTC also dismissed the case against Atty. Debuque due to his death.
  • The Court reiterated that once an information is filed in court, the trial court has the discretion to dismiss, convict, or acquit the accused, independent of the prosecutor's op...continue reading

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