Case Digest (G.R. No. 161178)
Facts:
Adela B. Delgado v. People of the Philippines and Emmanuel Ang Jaranilla, G.R. No. 161178, February 05, 2010, the Supreme Court Third Division, Velasco Jr., J., writing for the Court.
Petitioner Adela B. Delgado was charged with estafa in the Regional Trial Court (RTC), Branch 54, Manila, in Crim. Case No. 95-142409, following a complaint filed by private respondent Emmanuel Ang Jaranilla. The information alleged that on or about July 9, 1993, Delgado, by false representations that she possessed USD 74,000 and needed Philippine pesos, induced Jaranilla to deliver PhP 2,029,820 in exchange for the dollars, and then absconded and converted the peso proceeds to her own use.
The factual findings adopted by the trial court were that Jaranilla, who was engaged in money-changing and had prior dealings with Delgado, agreed to exchange USD 74,000 at PhP 27.43 per dollar after consulting his father, Manuel Ang. Manuel Ang issued Metrobank Check No. 061224813 for PhP 2,029,820 payable to cash. Jaranilla’s secretary, Fely Aquino (also known as Lily Ang), met Delgado at the Binondo Metrobank branch on July 9, 1993; both endorsed the check and Aquino encashed it, whereupon Delgado received PhP 2,029,820, said she would fetch the dollars from her car, and left without returning. Despite repeated demands by Jaranilla, Delgado did not deliver the USD 74,000.
At trial, Delgado testified she had met Aquino only that afternoon and that one Carina Alabado delivered the dollars to Aquino; Aquino denied this. The RTC found the prosecution witnesses more credible and, in a July 15, 1999 decision, convicted Delgado of estafa under Article 315 of the Revised Penal Code, sentenced her to 20 years’ reclusion temporal, and ordered indemnity of PhP 2,029,820 to Jaranilla with legal interest.
Both parties appealed to the Court of Appeals (CA). Jaranilla sought interest from date of extra-judicial demand, moral and exemplary damages, and attorney’s fees; Delgado challenged the credibility findings and the conviction. In a September 30, 2003 decision in CA-G.R. CR No. 23701, the CA affirmed the RTC conviction but modified the penalty under the Indeterminate Sentence Law, fixed the computation of legal interest from July 9, 1993, and awarded PhP 250,000 moral damages, PhP 250,000 exemplary damages, PhP 100,000 attorney’s fees, and costs.
Delgado filed a Petition for Review on Certiorari with the Supreme Court contesting the CA decision, principally arguing that ...(Pro-only)
Issues:
- Was private respondent Emmanuel Ang Jaranilla the proper injured party for purposes of estafa, or was Manuel Ang the true injured party, thereby affecting criminal liability?
- Does petitioner Delgado’s asserted status as a money-changer and alleged capacity to possess USD 74,000 negate the element of deceit required for estafa?
- Did the trial court commit reversible error in accrediting the testimony of Aquino over Delgado’s witness Alabado and thereby in fin...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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