Case Digest (G.R. No. 213640)
Facts:
Lucia Manuel y Cadiz v. People of the Philippines, G.R. No. 213640, April 12, 2023, Supreme Court Third Division, Gaerlan, J., writing for the Court.The prosecution filed an Information dated July 27, 2007 in the Regional Trial Court (RTC) of Malolos City, Branch 9, charging Lucia Manuel y Cadiz (petitioner) with Estafa under Article 315(2)(d) of the Revised Penal Code (RPC) for issuing ten postdated Philippine National Bank (PNB) checks in the name of Flordeliza Uy that were dishonored for the reason "Account Closed"; the total amount alleged in the Information and supporting papers exceeded P800,000. The RTC tried the case, received testimony from Ebot’s Farm employees and a PNB branch manager, and convicted petitioner of estafa in a Decision dated July 26, 2012, sentencing her to thirty years of reclusion perpetua and ordering indemnity to Uy.
Petitioner appealed to the Court of Appeals (CA). In a Decision dated February 21, 2014, the CA affirmed the RTC’s conviction but modified the penalty to an indeterminate sentence of twelve years prision mayor as minimum to thirty years reclusion perpetua as maximum; the CA concluded the prosecution had proven the elements of estafa despite the non-presentation of Uy because other witnesses established damage. Petitioner’s motion for reconsideration was denied by CA in a July 23, 2014 Resolution.
Petitioner then filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court before the Supreme Court. Attached to a Reply were an Affidavit of Desistance executed by Uy and the Municipal Trial Court (MTC) Order dated July 29, 2015 dismissing related B.P. Blg. 22 cases after Uy testified and repudiated material allegations of the complaint. The Office of the Solicitor General (OSG) opposed admitting Uy’s affidavit and testimony from the separa...(Pro-only)
Issues:
- Under a Rule 45 petition for review on certiorari, may this Court revisit the factual findings of the lower courts in this case?
- Are Uy’s Affidavit of Desistance and her testimony given in a separate B.P. Blg. 22 proceeding admissible and of probative value in the instant estafa case?
- Did the prosecution prove beyond reasonable doubt the elements of Estafa under Article 315(2)(d) RPC—in particular, deceit and damage—so as to sustain petitioner’s conviction?
- Does petitioner’s acquittal also extinguish an...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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