Case Digest (G.R. No. L-11024)
Case Digest (G.R. No. L-11024)
Facts:
Ong Chiu Kwan v. Court of Appeals and the People of the Philippines, G.R. No. 113006, November 23, 2000, Supreme Court First Division, Pardo, J., writing for the Court.On January 31, 1991, the Assistant City Prosecutor of Bacolod filed an information in the Municipal Trial Court (MTC), Bacolod City, charging Ong Chiu Kwan with unjust vexation under Article 287, par. 2 of the Revised Penal Code for ordering the cutting of the electric wires, water pipes and telephone lines servicing "Crazy Feet," a business owned by Mildred Ong. The incident occurred on April 24, 1990, when petitioner instructed Wilfredo Infante to "relocate" those lines because they allegedly crossed his property; petitioner did not present any permit or authorization to relocate or cut the lines.
After trial, the MTC convicted petitioner on September 1, 1992, sentencing him to "imprisonment for twenty days" (the court later noted the terminology was incorrect) and awarding P10,000 moral damages, P5,000 exemplary damages, P5,000 attorney's fees, plus costs, on the ground the interruption occurred during the business's peak hours and harmed the proprietor. The Regional Trial Court (RTC), Bacolod City, in a decision dated December 8, 1992, affirmed the MTC "in toto" by quoting that judgment and adding perfunctory paragraphs that merely stated it had no ground to modify the lower court's decision.
Petitioner appealed to the Court of Appeals (docketed CA-G.R. CR No. 14209). On August 16, 1993, the Court of Appeals, with Tayao-Jaguros, J., as ponente, affirmed the lower courts' conviction. Petitioner filed a petition for review with the Supreme Court on January 14, 1994; the Supreme Court gave the petition due course on March 1, 2000. The Supreme Court First Division took up the case and reviewed both procedural and substantive issues, including the RTC's peremptory affirmation and the sufficiency of proof for conviction and damages.
Issues:
- Was the Regional Trial Court's decision that merely adopted the Municipal Trial Court's judgment a valid decision, or was it a nullity for failing to state clearly and distinctly the facts and law on which it was based?
- Did petitioner commit the crime of unjust vexation when he ordered the cutting of the electric, water and telephone lines supplying the complainant's business?
- Were the awards of moral damages, exemplary damages, and attorney's fees properly granted?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)