G.R. No. 117363 - Pangili vs. Court of Appeals

The petitioner, Mila G. Pangilinan, was charged on September 20, 1990, with the crime of estafa.
The information alleged that on or about June 15, 1984, in Tanay, Rizal, the petitioner, under false pretenses, obtained a stereo component, headphones, an electrical jack, and record tapes from the residence of spouses Rolando and Soledad Elnar.
It was further alleged that the petitioner misrepresented herself by claiming to have instructions from Mr. Rodolfo Elnar regarding testing the stereo component at a designated location, thereby inducing the minor Luzviminda SJ Elnar to deliver these items.
The information stated that these acts were committed through fraud and abuse of confidence, with the value of the items amounting to P17,450.00.

On March 12, 1991, the petitioner was arraigned before the Regional Trial Court (RTC) of Morong, Rizal, where she pleaded “not guilty.”
After due trial, on October 7, 1992, the RTC convicted the petitioner of estafa under Article 315 of the Revised Penal Code, issuing a sentence that included imprisonment and an order to pay damages.
The conviction was appealed to the Court of Appeals (CA), which, on August 13, 1993, affirmed the conviction but modified the sentence to four (4) months of arresto mayor and a fine of P17,450.00, with subsidiary imprisonment in case of insolvency.
Subsequent motions for reconsideration and a petition for new trial were denied by the CA in November 1993 and January 1994, respectively.

The RTC’s decision was null and void due to lack of jurisdiction over the case.
Alternatively, even if jurisdiction were presumed, the evidence did not prove her guilt beyond reasonable doubt.

The controversy centered on the classification of the offense. Although the information generically mentioned “estafa,” the trial court presumed that the petitioner was charged under Article 315 of the Revised Penal Code.
Critical elements for estafa by abuse of confidence—specifically, the allegation of a demand made by the offended party—were not properly alleged in the information.

A significant point of contention was that, under Section 32 of Batas Pambansa Blg. 129, offenses punishable by imprisonment not exceeding four years and two months (or a certain fine) fall under the exclusive original jurisdiction of the Municipal Trial Courts, not the RTC.
The petitioner argued that her case should have been filed and tried in a Municipal Trial Court rather than the RTC.
The Office of the Solicitor General (OSG) contended that the petitioner was estopped from raising the jurisdictional issue, relying on established precedent regarding estoppel and affirmative relief.
The petitioner rebutted the estoppel argument by asserting that jurisdiction is vested by law and may be questioned at any stage of the proceedings.

The trial court assumed jurisdiction and convicted the petitioner for estafa under Article 315.
The appellate court, while modifying the sentence, did not squarely address the underlying issue of jurisdiction, instead focusing on the modified offense under Article 318 (the generic “Other Deceits”).
Ultimately, the high court undertook a careful examination of the allegations, statutory mandates, and pertinent precedents, questioning both the sufficiency of the charge and the proper forum for the trial.

Whether the conviction rendered by the RTC was valid, given that the offense charged fell within the exclusive original jurisdiction of the Municipal Trial Court under Section 32 of B.P. 129.
Whether the failure to allege an essential element (i.e., the demand by the offended party) in the information also affected the proper classification of the offense.

Whether, assuming the RTC had jurisdiction, the evidence was sufficient to prove the petitioner’s guilt beyond reasonable doubt.
Whether the alternative argument—that the petitioner’s guilt was not adequately proven—warrants a reversal of the conviction.

Whether the petitioner is barred by estoppel from challenging the jurisdiction of the trial court, considering that she did not initially invoke jurisdiction as an affirmative defense.
The extent to which the doctrine of estoppel applies to jurisdictional issues when the error in jurisdiction is apparent from statutory provisions.