Case Digest (G.R. No. 210318) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Janice Reside y Tan v. People of the Philippines, petitioner Janice Reside y Tan served from 2001 to 2005 as Pre-School and Grade School Principal of Treasury of the Golden Word School, Inc. (TGWSI) in Las Piñas City. By verbal agreement with TGWSI President Carmelita C. De Dios, she was entrusted to collect tuition and other school payments, issue official receipts, and remit the proceeds to the school. In 2005, TGWSI Treasurer Marie Gil Padilla discovered that petitioner had stopped reporting for work and that significant sums of tuition were unremitted. A review of school records revealed discrepancies between receipts issued and remittance vouchers. At a barangay mediation, petitioner admitted the shortfall and signed a promissory note to repay ₱1,721,010.82 within three months. When she failed to satisfy the obligation, De Dios filed an estafa complaint. The Regional Trial Court (RTC) of Las Piñas City, Branch 201, in its April 8, 2011 Decision, convicted petitioner of e Case Digest (G.R. No. 210318) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Information and arraignment
- Petitioner Janice Reside y Tan, as pre-school and grade school principal of Treasury of the Golden Word School, Inc. (TGWSI), was charged in 2006 under Art. 315(1)(b) RPC for estafa in the amount of ₱1,721,010.82.
- The Information alleged she was authorized to collect tuition fees, issue receipts, remit collections to TGWSI, but misappropriated and converted the entire amount to her own use despite demand.
- Investigation and promissory note
- In 2005, the Treasurer and President of TGWSI discovered unremitted tuition fees and irregular use of temporary receipts.
- At a barangay settlement, petitioner admitted the allegations and signed a promissory note to pay within three months; she defaulted, prompting a criminal complaint.
- Trial court and Court of Appeals decisions
- RTC (April 8, 2011) found all elements of estafa proven, convicted petitioner of estafa under Art. 315(1)(b) RPC, and sentenced her to 8 years prision mayor (medium) to 17 years 4 months 1 day reclusion temporal, plus indemnity of ₱1,721,010.82 and attorney’s fees.
- CA (June 28, 2013) affirmed guilt but reduced the misappropriated amount to ₱134,462.90, modified the penalty to 4 years 2 months prision correccional minimum to 17 years 4 months 1 day reclusion temporal, and ordered indemnity of ₱134,462.90 plus 10% attorney’s fees.
- CA denied petitioner’s motion for reconsideration on November 26, 2013. Petitioner filed a Rule 45 petition to the Supreme Court.
Issues:
- Whether the elements of estafa under Article 315(1)(b) RPC were sufficiently established, in particular:
- If petitioner acquired juridical possession of the funds entrusted to her.
- If misappropriation and demand were shown.
- If estafa is not proven, whether qualified theft is necessarily included in the information and may be the basis for conviction under the variance doctrine (Rule 120, Secs. 4 & 5, Revised Rules on Criminal Procedure).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)