Title
Jacinto vs. People
Case
G.R. No. 162540
Decision Date
Jul 13, 2009
In the case of Jacinto v. People, a woman is found guilty of an impossible crime instead of qualified theft after attempting to steal a dishonored check, leading to a discussion on the concept of an impossible crime and the elements of theft.
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Case Digest (G.R. No. 162540)

Facts:

  • Petitioner Gemma T. Jacinto, along with Anita Busog de Valencia y Rivera and Jacqueline Capitle, was charged with Qualified Theft.
  • The incident occurred in July 1997 in Caloocan City, Metro Manila.
  • The accused were employees of Mega Foam International Inc., represented by Joseph Dyhengco.
  • They allegedly conspired to steal Banco De Oro Check No. 0132649, dated July 14, 1997, for P10,000.00, which was payment from a customer, Baby Aquino, to Mega Foam.
  • The check was deposited in the Land Bank account of Generoso Capitle, husband of Jacqueline Capitle.
  • The check was dishonored, leading to an entrapment operation by the NBI, resulting in the arrest of Jacinto and Valencia.
  • The RTC found Jacinto, Valencia, and Capitle guilty of Qualified Theft, with Jacinto and Valencia sentenced to imprisonment.
  • The Court of Appeals affirmed Jacinto's conviction but reduced Valencia's sentence and acquitted Capitle.
  • Jacinto filed a petition for review on certiorari, questioning her conviction.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted the petition, modifying the CA's decision.
  • Jacinto was found guilty of an Impossible Crime as defined in Articles 4, paragraph 2, and 59 of the Revised Penal Code....(Unlock)

Ratio:

  • The prosecution failed to establish the elements of Qualified Theft as the check was dishonored and had no value.
  • Applying the doctrine from "Intod v. Court of Appeals," the Court ruled that an impossible crime occurs when the intended crime is inherently impossible due to unknown extraneous circumstances.
  • Jacinto's act of takin...continue reading

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