Title
People vs. Digoro
Case
G.R. No. L-22032
Decision Date
Mar 4, 1966
Camolo Digoro pleaded guilty to illegal possession of counterfeit notes, but the Supreme Court ruled the charge defective for lacking "intent to use," remanding for proper prosecution.

Case Digest (G.R. No. L-12300)
Expanded Legal Reasoning Model

Facts:

  • Initial Criminal Information and Proceedings
    • June 3, 1959 – The Provincial Fiscal of Lanao files an information in the Court of First Instance charging Camolo Digoro alias Panondiongan, Hadji Solaiman Digoro, and Macasasab Dalomangcob with Counterfeiting of Treasury and Bank Notes under Article 166 of the Revised Penal Code.
    • June 5 and August 13, 1959 – Amended informations for the same offense are filed.
    • August 14, 1959 – Upon arraignment, all three accused plead not guilty.
  • Subsequent Dismissal, Amended Information, Plea, and Lower Court Judgment
    • March 20, 1961 – The Provincial Fiscal moves to provisionally dismiss the case against Hadji Solaiman Digoro and Macasasab Dalomangcob; the court grants the motion.
    • March 20, 1961 – On the same date, an amended information is filed against Camolo Digoro alias Panondiongan for “Illegal Possession of Counterfeit Treasury and Bank Notes,” alleging:
      • Possession, custody, and control of various denominations of counterfeit Philippine treasury or bank notes.
      • An “intent to possess” such false notes, enumerated in twenty-one detailed items with serial numbers and quantities.
    • March 20, 1961 – Digoro, with counsel, enters a plea of guilty to the amended information.
    • The trial court renders judgment sentencing Digoro to imprisonment of not more than ten years and one day nor less than six years and one day, plus costs.
  • Appeal and Certification to the Supreme Court
    • Digoro appeals to the Court of Appeals on the ground that the amended information does not charge an offense.
    • September 11, 1963 – The Court of Appeals certifies the case to the Supreme Court, stating that the questions involved are purely of law.

Issues:

  • Whether an information alleging only possession of false treasury and bank notes “with intent to possess,” but not alleging “intent to use,” states an offense under Article 168 of the Revised Penal Code.
  • Whether a plea of guilty to an information that fails to allege the necessary intent to use warrants a valid conviction.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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