G.R. No. 143581 - Korea Technologies Co., Ltd. vs. Lerma

Ong Chiu Kwan was charged with unjust vexation under Article 287, par. 2 of the Revised Penal Code for cutting the electric wires, water pipes, and telephone lines servicing "Crazy Feet," a business owned by Mildred Ong.
The complaint was filed by Assistant City Prosecutor Andres M. Bayona with the Municipal Trial Court of Bacolod City on January 31, 1991.

On April 24, 1990, at around 10:00 AM, Ong Chiu Kwan ordered Wilfredo Infante to “relocate” the telephone, electric, and water lines of "Crazy Feet," claiming that these lines posed a disturbance.
Ong Chiu Kwan did not obtain any permit or authorization from appropriate authorities to cut or relocate these lines.
The interruption occurred during the peak business hours of the establishment, causing the owner operational losses.

The Municipal Trial Court, in a decision dated September 1, 1992, found Ong Chiu Kwan guilty beyond reasonable doubt of unjust vexation and sentenced him to imprisonment for twenty days (arresto menor).
The trial court also awarded moral damages of P10,000.00, exemplary damages of P5,000.00, attorney’s fees of P5,000.00, and costs.
The Regional Trial Court of Bacolod City affirmed the Municipal Trial Court’s decision without stating its own reasons, merely adopting the lower court’s ruling in toto in a decision dated December 8, 1992.

Ong Chiu Kwan filed a petition for review before the Court of Appeals on April 22, 1993.
On August 16, 1993, the Court of Appeals dismissed the appeal and affirmed the conviction for unjust vexation.
Thereafter, Ong Chiu Kwan elevated the case to the Supreme Court by petition for review, which was given due course on March 1, 2000.

The Supreme Court noted that the Regional Trial Court’s decision was a nullity because it did not comply with the constitutional and procedural requirements for decisions; it lacked a clear and distinct statement of facts and law that form the basis of the judgment.
The Regional Trial Court merely quoted the lower court’s decision verbatim and did not independently discuss or evaluate the evidence or law.
The Court emphasized the constitutional mandate (Article VIII, Section 14) and the 1985 Rules of Criminal Procedure (Rule 120, Sec. 2) requiring written decisions to contain clear findings of fact and law, personally prepared and signed by the judge.

Whether the conviction of Ong Chiu Kwan for unjust vexation is proper
Whether the Regional Trial Court’s decision is valid and complies with the constitutional and procedural requirements for court decisions
Whether the awards of moral damages, exemplary damages, and attorney's fees were properly given