Case Digest (G.R. No. 179018) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioner Gemma T. Jacinto worked as a collector for Mega Foam International, Inc. In June 1997, customer Baby Aquino handed her Banco de Oro Check No. 0132649 dated July 14, 1997, for ₱10,000 as payment for purchases. Instead of remitting this check to her employer, Jacinto conspired with fellow employees Anita Busog de Valencia y Rivera and Jacqueline Capitle to have it deposited into the Land Bank account of Capitle’s husband. The check bounced for lack of funds. Upon discovery, the owner of Mega Foam engaged the National Bureau of Investigation (NBI) and conducted an entrapment operation using ten marked ₱1,000 bills. On August 21, 1997, during a rendezvous intended to replace the dishonored check with cash, Jacinto and Valencia were arrested by NBI agents while handling the marked money. On October 4, 1999, the Regional Trial Court (RTC) of Caloocan City, Branch 131, found all three accused guilty of Qualified Theft under Articles 308 and 310 of the Revised Penal Code and Case Digest (G.R. No. 179018) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Petitioner Gemma T. Jacinto, together with Anita Busog de Valencia and Jacqueline Capitle, was charged before the Regional Trial Court (RTC) of Caloocan City, Branch 131, with Qualified Theft for allegedly taking Banco de Oro Check No. 0132649 dated July 14, 1997 worth ₱10,000.00, representing payment by customer Isabelita “Baby” Aquino to Mega Foam International, Inc.
- On October 4, 1999, the RTC found all three accused guilty of Qualified Theft and sentenced each to 5 years, 5 months, and 11 days to 6 years, 8 months, and 20 days imprisonment. On December 16, 2003, the Court of Appeals (CA) modified the RTC decision: it affirmed Jacinto’s sentence, reduced Valencia’s to 4 months arresto mayor medium, and acquitted Capitle. A motion for reconsideration by Jacinto was denied on March 5, 2004.
- Underlying Events
- In June 1997, Baby Aquino handed petitioner a postdated BDO check for ₱10,000.00 as payment for purchases from Mega Foam, where Jacinto was a collector. The check was never remitted to the company but was deposited into the Land Bank account of Generoso Capitle, Jacqueline’s husband.
- Upon dishonor of the check, a scheme emerged among Mega Foam employees—Jacinto, Anita Valencia, Jacqueline Capitle, and Rowena Ricablanca—to have Aquino replace the bounced check with cash and divide the proceeds equally.
- The owner, Joseph Dyhengco, coordinated with the NBI for an entrapment. Marked bills dusted with fluorescent powder were used. On August 21, 1997, Ricablanca met Jacinto at her home, received the bounced check, and returned later acting as intermediary for cash replacement. Jacinto and Valencia each received ₱5,000.00 in marked money, were arrested by NBI agents, and later tested positive for fluorescent powder.
- Defense Account
- Jacinto and Valencia admitted resigning June 30, 1997 and claimed they merely gave Ricablanca a ride in their jeep to Aquino’s house for unrelated reasons. They denied knowledge of any theft and were surprised by their arrest.
- Jacqueline Capitle similarly disavowed participation and was acquitted by the CA.
Issues:
- Whether petitioner can be convicted of a crime not charged in the Information.
- Whether a worthless (dishonored) check can be the object of theft.
- Whether the prosecution proved petitioner’s guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)