Case Digest (G.R. No. 234818) Core Legal Reasoning Model
Facts:
The case People of the Philippines v. Felix Aquino involves an appeal filed by Felix Aquino (accused-appellant) assailing the July 28, 2017 Decision of the Court of Appeals (CA), which affirmed the Regional Trial Court (RTC) of Makati City's Joint Decision dated July 22, 2014, later partly revised by an August 8, 2014 Order. Felix was charged and convicted of twenty-one counts of Syndicated Estafa under Article 315(2)(a) of the Revised Penal Code (RPC), in relation to Presidential Decree No. 1689. Alongside Felix, several co-accused persons including his spouse Iris Aquino (deceased) and others at-large were charged.
The case arose from thirty-three separate Informations filed before the RTC, each charging Felix and his co-accused of defrauding private complainants through their roles as officers/directors of Everflow Group of Companies. Between 2000 and 2002, the private complainants alleged that Felix and Iris induced them to invest money into Everflow, promising high ret
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Case Digest (G.R. No. 234818) Expanded Legal Reasoning Model
Facts:
- Background of the Case
- Thirty-three (33) separate Informations were filed before the Regional Trial Court (RTC) of Makati City charging Felix Aquino (Felix), his late spouse Iris Aquino, and five other co-accused with syndicate estafa under Article 315 (2)(a) of the Revised Penal Code (RPC) in relation to Presidential Decree No. 1689.
- The accused were officers/directors of Everflow Group of Companies, Inc. (Everflow), which solicited investment funds from the public, promising high monthly returns.
- Details of the Crime
- Private complainants alleged that between 2000 and 2002, they were induced by Felix and Iris to invest money in Everflow based on promises of 70% interest, doubling in more than a year, and 5% monthly interest.
- Investments amounted to P5,161,211.28 and US$90,981.00 from different complainants.
- After the Securities and Exchange Commission issued a Cease and Desist Order against Everflow, it shut down. Demands to return the investments were refused.
- Multiple charges of syndicated estafa were filed against Felix, Iris, and the other co-accused, but only Felix and Iris were arrested and arraigned, the others remain at large.
- Trial Proceedings
- Eleven (11) counts were provisionally dismissed due to complainants’ failure to appear.
- Felix and Iris denied charges, claiming they were victims of a certain Rosario Baladjay and assured that investments were passed on to Multinational Telecom Investors Corporation (Multitel).
- Iris died during the proceedings, and the cases against her were dismissed.
- RTC Decisions
- In a Joint Decision dated July 22, 2014, the RTC found Felix guilty beyond reasonable doubt of 16 counts of syndicated estafa and sentenced him to life imprisonment for each.
- The court ordered Felix to pay actual damages totaling P2,323,504.00 and US$4,983.00 with legal interest from the filing of the Informations until fully paid.
- An Order dated August 8, 2014 modified the conviction to 21 counts, clarifying civil liability only to 16 complainants due to evidentiary deficiencies in five others.
- Court of Appeals (CA) Ruling
- On July 28, 2017, the CA affirmed the RTC’s ruling in toto, upholding Felix’s conviction.
- The CA emphasized the fraudulent inducement, the issuance of dishonored checks drawn on closed accounts, and the lack of SEC authorization to solicit investments, which showed intent to defraud.
- Appeal to the Supreme Court
- Felix filed an ordinary appeal to the Supreme Court contesting the CA decision.
Issues:
- Whether or not Felix Aquino is guilty beyond reasonable doubt of syndicate estafa defined under Article 315 (2)(a) of the Revised Penal Code in relation to PD 1689.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)