Case Digest (G.R. No. 192881) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Jose C. Go, Aida C. Dela Rosa, and Felecitas D. Necomedes (G.R. No. 191015, August 6, 2014), the Bangko Sentral ng Pilipinas closed Orient Commercial Banking Corporation (OCBC) on October 14, 1998 and appointed the Philippine Deposit Insurance Corporation (PDIC) as receiver. PDIC sent demand letters to OCBC borrowers, including Timmy’s, Inc. and Asia Textile Mills, Inc., which denied any loans. Investigation revealed that two manager’s checks for ₱9,985,075.00 each—coded to those alleged loans—were instead issued to Zeta International, Inc. and Philippine Recyclers, Inc., encashed, and deposited into respondent Jose Go’s OCBC accounts, then used to fund personal checks. On September 24, 1999, PDIC filed two counts of estafa through falsification of commercial documents against respondents before the City Prosecutor of Manila; informations were filed on November 22, 2000 in RTC Manila (Criminal Cases 00-187318 and 00-187319). After the prosecution Case Digest (G.R. No. 192881) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Investigation
- On October 14, 1998, the Bangko Sentral ng Pilipinas (BSP) closed Orient Commercial Banking Corporation (OCBC) and placed it under Philippine Deposit Insurance Corporation (PDIC) receivership.
- As receiver, PDIC took over OCBC’s assets and liabilities and began collecting on past‐due loans by sending demand letters to listed borrowers, including “Timmy’s, Inc.” and “Asia Textile Mills, Inc.” alleging P 10 million loans each.
- Denials and Findings
- Representatives of Timmy’s, Inc. and Asia Textile Mills, Inc. denied any OCBC loans, claiming their signatures on loan documents were forged.
- PDIC’s investigation showed that two manager’s checks, coded CL-484 and CL-477 (each for P 9,985,075.00), purported loan proceeds of these entities, were issued to Philippine Recyclers, Inc. and Zeta International, Inc., then deposited into respondent Jose C. Go’s OCBC savings account.
- Criminal Proceedings
- September 24, 1999 – PDIC filed an Estafa through Falsification of Commercial Documents complaint against respondents Go, Aida C. Dela Rosa (OCBC SVP/COO and Loan Committee member), and Felecitas D. Necomedes (OCBC Senior Manager).
- November 22, 2000 – Informations were filed in the RTC Manila (Criminal Cases 00-187318 and 00-187319). Respondents pleaded not guilty; pretrial and trial ensued.
- Demurrer and Acquittal
- December 19, 2006 – RTC granted leave to file demurrer to evidence.
- January 17, 2007 – Respondents filed Demurrer to Evidence.
- July 2, 2007 – RTC dismissed cases and acquitted respondents for insufficiency of prosecution evidence.
- October 19, 2007 – RTC denied the private prosecutor’s motion for reconsideration; the public prosecutor (Campanilla) did not timely move for reconsideration, raising questions on conformity.
- Court of Appeals and Supreme Court Review
- January 4, 2008 – Office of the Solicitor General filed petition for certiorari with CA.
- September 30, 2009 – CA denied petition, affirmed RTC acquittal as final for failure of public prosecutor to move for reconsideration, invoking double jeopardy.
- January 22, 2010 – CA denied reconsideration.
- August 6, 2014 – Supreme Court promulgated decision granting petition for review on certiorari.
Issues:
- Whether the Court of Appeals erred in ruling that:
- The RTC committed no grave abuse of discretion in granting the demurrer to evidence.
- The RTC’s acquittal order attained finality for lack of timely motion for reconsideration by the public prosecutor.
- The alleged errors were errors of judgment, not jurisdiction, thus foreclosing certiorari relief.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)