Case Digest (G.R. No. 226590) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Shirley T. Lim, Mary T. Lim-Leon and Jimmy T. Lim v. People of the Philippines (G.R. No. 226590, April 23, 2018), petitioners Shirley, Mary and Jimmy Lim, all officers of Pentel Merchandising Co., Inc., were charged with falsification of a public document under Articles 171 and 172 of the Revised Penal Code. Their father, Quintin C. Lim, who had served as one of Pentel’s directors, died on September 16, 1996. On February 25, 2000, a purported board meeting was certified in a Secretary’s Certificate dated February 29, 2000, to have approved the sale of a parcel of land in Pasay City, bearing Quintin’s signature. On March 21, 2000, Jimmy entered into a Deed of Absolute Sale with the Spouses Lee, and on March 29, 2000, Transfer Certificate of Title No. 129824 was cancelled and TCT No. 142595 was issued in favor of the Spouses Lee. Stockholder Lucy Lim later executed an Affidavit of Complaint dated September 21, 2010, alleging that petitioners forged Quintin’s signature on the Se Case Digest (G.R. No. 226590) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Roles
- Petitioners: Shirley T. Lim (Corporate Secretary), Mary T. Lim-Leon, and Jimmy T. Lim, siblings and officers of Pentel Merchandising Co., Inc. (“Pentel”).
- Respondent: People of the Philippines, represented by private prosecutor Lucy Lim and the Manila City Prosecutor’s Office.
- Factual Antecedents
- Death of corporate founder: Quintin C. Lim died on September 16, 1996.
- Allegation of falsification: In an Affidavit of Complaint dated September 21, 2010, Lucy Lim alleged that petitioners falsified a Secretary’s Certificate dated February 29, 2000, which contained Pentel Board Resolution 2000-001 dated February 25, 2000, authorizing Jimmy to sell a Pasay City property registered under TCT No. 129824.
- Transaction and Registration
- Deed of Absolute Sale: Jimmy, purportedly under the authority of the falsified Secretary’s Certificate, executed a Deed of Absolute Sale on March 21, 2000, conveying the subject property to Spouses Emerson and Doris Lee.
- Title transfer and registry records: On March 29, 2000, TCT No. 129824 was cancelled; in lieu thereof, TCT No. 142595 was issued in favor of the Spouses Lee. The Records Officer of the Pasay City Registry of Deeds so testified.
- Procedural History
- MeTC (April 29, 2014): Convicted petitioners of falsification of a public document (Art. 172, RPC), acquitted Spouses Lee; sentenced to prision correccional (2y4m–4y9m11d) and fine.
- RTC (November 27, 2014): Denied appeal, affirmed MeTC decision in toto; denied reconsideration (Feb 16, 2015).
- CA (April 22, 2016; mod. August 17, 2016): Denied petition for review, modified penalty under Indeterminate Sentence Law to 2y4m–4y9m10d prision correccional; denied reconsideration.
- Supreme Court Rule 45 petition: Filed by petitioners, raising same arguments and, for the first time on appeal, prescription of the offense.
Issues:
- Whether the petitioners were properly charged and convicted for falsification of a public document under Article 172 of the Revised Penal Code.
- Whether the crime of falsification of a public document had already prescribed at the time the Information was filed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)