Case Digest (G.R. No. 44892)
Facts:
- Simeon Capule served as the president of the Orient Protective Assurance Association, a mutual benefit society in the Philippines.
- Between November 1934 and May 1935, he faced accusations of misappropriating funds from the travelers' accident fund for unauthorized uses.
- The trial court determined that Capule had diverted funds for expenses unrelated to member benefits, including office equipment and printing costs.
- The lower court ruled against him, imposing a fine of one hundred pesos and subsidiary imprisonment if he became insolvent.
- Capule appealed, claiming that the treasurer was responsible for the funds and that temporary borrowing from the fund did not constitute a legal violation.
Issue:
- (Unlock)
Ruling:
- The Supreme Court upheld the lower court's judgment, affirming Capule's responsibility for the violation of Section 1628-E.
- The Court concluded that diverting funds from the travelers' accident fund constituted a legal breach. ...(Unlock)
Ratio:
- The Court interpreted Section 1628-E, which requires that benefit funds be used exclusively for authorized benefits and related operational expenses.
- The travelers' accident fund was categorized as a relief fund, and using these funds for office equipment was deemed impermissible.
- The association's by-laws assigned operational responsibility t...continue reading
Case Digest (G.R. No. 44892)
Facts:
In the case of People vs. Capule, G.R. No. 44892, decided on May 31, 1938, the defendant, Simeon Capule, served as the president of the Orient Protective Assurance Association, a mutual benefit, relief, and benevolent society incorporated under Philippine law. The case stemmed from allegations that between November 1934 and May 1935, Capule misappropriated funds from the travelers' accident fund of the association for unauthorized purposes, contravening Section 1628-E of the Revised Administrative Code. The trial court's findings revealed that Capule had diverted a portion of the fund to cover expenses unrelated to member benefits, such as costs for office equipment, furniture, and printing. Consequently, the lower court ruled against Capule, imposing a fine of one hundred pesos and subsidiary imprisonment in the event of insolvency. In response to the ruling, Capule appealed, arguing that the treasurer, rather than the president, bore responsibility for the funds and contended that temporarily borrowing from the fund did not equate to a legal violation.
Issue:
- Did the lower court err in holding that Simeon Capule, as president of the Orient Protective Assurance Association, was responsible for the violation of Section 1628-E of the Revised Administrative Code?
- Was the diversion ...