Title
People vs. Capule
Case
G.R. No. 44892
Decision Date
May 31, 1938
In the Philippine Jurisprudence case of People v. Capule, defendant Simeon Capule, president of the Orient Protective Assurance Association, is found guilty of diverting funds from the travelers' accident fund for unauthorized purposes, violating section 1628-E of the Revised Administrative Code, resulting in a fine and subsidiary imprisonment.
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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

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