Case Digest (G.R. No. 231298) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People v. Estoconing, Roberto A. Estoconing, general manager of the Silliman University Cooperative and professor at Silliman University, was charged on January 9, 2012 with willfully and criminally refusing to extend a 20% senior citizen discount to Manuel Utzurrum Jr., a bona fide senior citizen who purchased Mountain Dew soft drinks eight times between March 30 and September 22, 2011. Utzurrum identified himself and presented his Senior Citizen ID on each occasion, but the cooperative denied the discount. He wrote letters to Estoconing, filed a complaint with the local Office for Senior Citizen Affairs, and obtained a barangay certificate authorizing the filing of formal charges. Estoconing pleaded not guilty, asserting that the cooperative was exempt under the Philippine Cooperative Code of 2008 (RA 9520) as a Cooperative Development Authority-registered, tax-exempt entity, and that its members already received a patronage refund, invoking the no double discount rule unde Case Digest (G.R. No. 231298) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Roberto A. Estoconing (petitioner) – professor at Silliman University and general manager of the Silliman University Cooperative.
- Manuel Utzurrum Jr. (private complainant) – bonafide senior citizen and member-owner of the cooperative, holder of Senior Citizen I.D. No. 1535115.
- Transactions and Complaint
- Utzurrum purchased eight soft drinks between March and September 2011 at the Cooperative’s canteen; each time he presented his Senior Citizen ID but was denied the 20% discount mandated by law.
- He sent several letters to Estoconing and filed complaints with the Office of Senior Citizen Affairs and the barangay, securing a certificate to file action on October 8, 2011.
- Information and Plea
- On January 9, 2012, an Information was filed charging Estoconing with willful refusal to grant the discount, contrary to Republic Act (RA) No. 7432 as amended by RA No. 9994 (the Expanded Senior Citizens Act of 2010).
- Estoconing pleaded not guilty, asserting exemption of the cooperative under the Cooperative Code (RA No. 9520) and the no–double–discount rule (patronage refund vs. senior discount).
- Proceedings Below
- Municipal Trial Court in Cities (Branch 2, Dumaguete City) – found Estoconing guilty; imposed an indeterminate sentence of two to three years’ imprisonment and a ₱50,000 fine.
- Regional Trial Court (Branch 32, Dumaguete City) – affirmed the conviction in toto on December 18, 2014.
- Court of Appeals (Special Eighteenth Division, Cebu City) – dismissed Estoconing’s petition on July 29, 2016; held that:
- The Expanded Senior Citizens Act applies to cooperatives.
- The no–double–discount rule did not cover patronage refunds.
- DTI Administrative Order on basic necessities and prime commodities did not exempt restaurants/canteens.
- Tax-exempt status did not relieve compliance with the discount mandate.
- Petition for Review on Certiorari
- Estoconing filed a Rule 45 petition before the Supreme Court, raising solely questions of law on the conflict between the Expanded Senior Citizens Act and the Cooperative Code.
- He submitted a May 24, 2019 opinion of the Cooperative Development Authority (CDA) but declined to file a formal reply.
Issues:
- Whether a cooperative duly registered under RA No. 9520 and enjoying tax exemptions may be compelled to grant the statutory 20% senior citizen discount when it cannot recoup the cost via tax deduction.
- Whether the provisions of the Expanded Senior Citizens Act (RA 7432, as amended by RA 9994) and the Cooperative Code (RA 9520) can be harmonized, or whether one law yields to the other.
- Whether requiring an uncompensated discount from a tax-exempt cooperative violates due process by effectively depriving it of property without just compensation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)