Case Digest (G.R. No. 111399) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Odon Pecho v. People of the Philippines and the Sandiganbayan (G.R. No. 111399, September 27, 1996), petitioner Odon Pecho, a former public official, was charged in Sandiganbayan Criminal Case No. 14844 with violation of Section 3(e) of R.A. No. 3019 for allegedly falsifying importation documents in collusion with his co-accused Joe Catre. The Sandiganbayan convicted him of the complex crime of attempted estafa through falsification of official and commercial documents under the Revised Penal Code, sentencing him to prision correccional to prision mayor and a fine of ₱2,000. On November 14, 1994, the Supreme Court modified the decision to convict him of that complex crime. Pecho filed a motion for reconsideration arguing (a) conviction under the Revised Penal Code after acquittal under a special anti-corruption law violated the constitutional double jeopardy clause, and (b) evidence was insufficient. The Office of the Solicitor General (OSG) initially challenged the double je Case Digest (G.R. No. 111399) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- The Sandiganbayan convicted Odon Pecho in Criminal Case No. 14844 for violation of Section 3(e), R.A. No. 3019, but the Supreme Court on November 14, 1994 modified the judgment, finding him guilty of the complex crime of attempted estafa through falsification of official and commercial documents (indeterminate penalty of 2 years, 4 months, 1 day to 10 years, 1 day plus ₱2,000 fine).
- Pecho filed a motion for reconsideration, arguing double jeopardy (acquittal under a special law precludes conviction under the general law) and insufficiency of evidence.
- The Office of the Solicitor General (OSG) initially opposed double jeopardy but joined in a plea for acquittal on the ground of insufficient circumstantial evidence. The Solicitor General confirmed this position in a September 14, 1995 manifestation.
- The Court required memoranda on (a) the sufficiency of evidence for the complex crime and (b) the validity of the conviction under the R.A. No. 3019 information versus the right to be informed of the accusation.
- Factual Circumstances
- Pecho and co-accused Joe Catre purported to represent “Eversun Commercial Trading” (a nonexistent entity) in engaging customs broker Constantino Calica to process import entry declarations at the Bureau of Customs.
- Trial evidence showed Catre alone negotiated terms, delivered documents (bill of lading, commercial invoices, packing list, importer’s sworn statement), and transacted with Calica. Pecho merely accompanied Catre; he did not introduce himself or handle documents.
- Evidence Presented
- Stenographic Notes (August 26, 1991) of Calica’s testimony:
- Only Catre spoke, introduced themselves as agents, and handed over the falsified documents.
- Pecho did not transact, was not named, and had no custody of the documents.
- No testimony or documentary evidence established Pecho’s knowledge of falsification or an overt act in furtherance of a conspiracy.
Issues:
- Whether the prosecution proved beyond reasonable doubt that Pecho is guilty of the complex crime of attempted estafa through falsification of public and commercial documents.
- Whether conviction for that complex crime under an information charging violation of Section 3(e), R.A. No. 3019, violates Pecho’s constitutional right (Section 14(2), Article III) to be informed of the nature and cause of the accusation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)