Case Digest (G.R. No. 246787) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Spouses Enrique Lloni Ilo and Marites Lloni Ilo were charged with the crime of Other Deceits under Article 318, first paragraph of the Revised Penal Code, for allegedly defrauding Pedro Joel Caspillo on March 30, 2009 in Makati City. The accusation was that they falsely represented that Unit H at 236 Aguho Street was free from encumbrances and that Caspillo was entitled to collect rent as interest for his loan of PHP 300,000.00. Caspillo lent the money based on these representations and executed a Memorandum of Agreement (MOA) with the spouses. Subsequently, Caspillo discovered that the unit was subject to other sangla-tira arrangements, and that the properties had been mortgaged to different banks, contrary to the spouses’ claims. The spouses denied the charges, claiming the transactions were brokered by their agent and that Caspillo knew about the mortgages. The Metropolitan Trial Court (MeTC) found them guilty, sentencing them to six months imprisonment and a fine of PHP 300, Case Digest (G.R. No. 246787) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Case
- Spouses Enrique and Marites Llonillo were charged with the crime of Other Deceits under Article 318, first paragraph of the Revised Penal Code.
- The complaint was filed by private complainant Pedro Joel Caspillo who entered into a sangla-tira arrangement with the spouses involving Unit H at No. 236 Aguho St., Barangay Comembo, Makati City.
- Caspillo lent spouses Llonillo PHP 300,000.00 on March 30, 2009, under the agreement that he would be entitled to collect rental payments from the unit as interest for the loan.
- Prosecution’s Allegations
- Spouses Llonillo assured Caspillo that the unit was free from encumbrances and could collect rental income.
- After lending the money, Caspillo discovered that the unit was mortgaged to different banks and was part of similar sangla-tira arrangements with other individuals.
- Spouses Llonillo failed to pay the principal and Caspillo was unable to collect the rental allegedly promised.
- Defense of the Spouses
- Marites Llonillo claimed she inherited the buildings and that a portion of the loan proceeds was received through their agent, Grace Pangan.
- They denied misrepresentation of the properties being free from liens or encumbrances.
- They explained that the sangla-tira arrangement and mortgages existed before the contract with Caspillo.
- Lower Court Decisions
- The Metropolitan Trial Court convicted spouses Llonillo of Other Deceits and ordered imprisonment and fines including restitution to Caspillo.
- The Regional Trial Court and Court of Appeals affirmed the conviction.
- Petition to the Supreme Court
- Spouses Llonillo filed a Petition for Review arguing among other things:
- Lack of jurisdiction due to a purportedly defective Information lacking prior written authority of the chief prosecutor.
- No fraudulent misrepresentation was committed since Caspillo possessed the unit and knew of mortgages.
- They could not be convicted for acts occurring after the execution of the contract.
Issues:
- Whether the Metropolitan Trial Court had jurisdiction to try and decide the case given the alleged defects in the Information.
- Whether spouses Llonillo were guilty beyond reasonable doubt of the crime of Other Deceits under Article 318 of the Revised Penal Code.
- Whether civil liability of spouses Llonillo for the unpaid loan can be adjudicated in the same criminal proceeding despite their acquittal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)