Case Digest (G.R. No. L-22237)
Facts:
In G.R. No. 181184 decided on January 25, 2012 under the 1987 Constitution, the petitioner Mel Dimat was charged with violating the Anti-Fencing Law (Presidential Decree No. 1612) before the Manila Regional Trial Court, Branch 03, in Criminal Case No. 02-202338. The prosecution presented Samson Delgado, Jose Mantequilla, and Police Officers Danilo Ramirez and Ruben Familara, who testified that in December 2000 Delgado’s wife bought from Dimat a 1997 Nissan Safari for ₱850,000.00 under a deed of sale reflecting engine No. TD42-126134 and chassis No. CRGY60-YO3553. On March 7, 2001, TMG officers stopped the Safari bearing plate WAH-569 on E. Rodriguez Avenue and discovered its true engine No. TD42-119136 and chassis No. CRGY60-YO3111, matching the description of the vehicle carnapped from owner Jose Mantequilla on May 25, 1998 at Robinsons Galleria. Mantequilla had mortgaged his Safari to RCBC and reported the theft. Dimat claimed he bought the vehicle in good faith as collateral ...Case Digest (G.R. No. L-22237)
Facts:
- Criminal charge and procedural history
- Accused Mel Dimat charged with violation of the Anti-Fencing Law (Presidential Decree No. 1612) before the Manila Regional Trial Court (RTC), Branch 03, Criminal Case No. 02-202338.
- RTC conviction (July 20, 2005): found guilty, sentenced to 10 years, 8 months, 1 day of prision mayor to 20 years reclusion temporal; ordered to pay ₱850,000 actual damages and ₱50,000 exemplary damages, plus costs.
- Court of Appeals (October 26, 2007) in CA-G.R. CR 29794 affirmed RTC decision but modified penalty to 8 years 1 day prision mayor (medium period) to 17 years 4 months 1 day reclusion temporal (maximum).
- Underlying facts and transactions
- December 2000: Sonia Delgado purchased a 1997 Nissan Safari (plate WAH-569) from Dimat for ₱850,000 per a deed of sale stating engine No. TD42-126134 and chassis No. CRGY60-YO3553.
- March 7, 2001: Police officers Ramirez and Familara of the Traffic Management Group spotted the Safari, discovered engine No. TD42-119136 and chassis No. CRGY60-YO3111 (numbers of a stolen vehicle on their list).
- Identification of stolen vehicle and owner’s testimony
- Vehicle traced to owner Jose Mantequilla, who mortgaged it to RCBC and reported its carnapping on May 25, 1998 at Robinsons Galleria.
- Mantequilla confirmed engine and chassis numbers (TD42-119136; CRGY60-YO3111) and that he never sold the vehicle to Dimat.
- Accused’s defense
- Dimat claimed he bought “in good faith” from Manuel Tolentino under a deed of sale matching the numbers in Delgado’s deed.
- He alleged the Safari he sold to Delgado was different from the one seized and insisted he did not know Mantequilla.
- Tolentino allegedly used the vehicle as collateral and promised new documents in Dimat’s name but failed to deliver.
Issues:
- Whether the Court of Appeals correctly ruled that Mel Dimat knowingly sold to Sonia Delgado a Nissan Safari that had been carnapped from Jose Mantequilla.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)