Case Digest (G.R. No. 119064) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Hannah Eunice D. Serana v. Sandiganbayan and People of the Philippines, G.R. No. 162059, decided January 22, 2008 under the 1987 Constitution, petitioner Hannah Eunice D. Serana, a senior student at the University of the Philippines Cebu appointed as UP Student Regent by President Estrada on December 21, 1999, co‐founded the Office of the Student Regent Foundation, Inc. (OSRFI) on September 4, 2000 with her brother Jade Ian Serana and relatives to undertake the renovation of Vinzons Hall Annex in UP Diliman. The OSRFI allegedly received a Land Bank check for Fifteen Million Pesos (P15,000,000.00) from the Office of the President on October 24, 2000, but the project never materialized. Successor student regent Kristine Bugayong and Christine Jill De Guzman filed a complaint before the Ombudsman for malversation and estafa. On July 3, 2003, the Ombudsman found probable cause to indict the Serenas in Sandiganbayan Criminal Case No. 27819 for estafa under Article 315(2)(a) of the Case Digest (G.R. No. 119064) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- Petitioner Hannah Eunice D. Serana, a University of the Philippines scholar, served as Student Regent from January 1 to December 31, 2000 by appointment of President Joseph Estrada.
- On September 4, 2000, petitioner and her relatives incorporated the Office of the Student Regent Foundation, Inc. (OSRFI) to undertake projects including the renovation of Vinzons Hall Annex, UP Diliman.
- President Estrada released Fifteen Million Pesos (₱15,000,000.00) to OSRFI as financial assistance for the renovation, which never occurred.
- Complaint and Indictment
- Successor student regent and student leaders filed a complaint for malversation with the Office of the Ombudsman.
- On July 3, 2003, the Ombudsman found probable cause and indicted petitioner and her brother under Article 315(2)(a) of the Revised Penal Code for estafa, docketed as Sandiganbayan Criminal Case No. 27819.
- The Information alleges that petitioner, using her position, defrauded the government by falsely representing the renovation project to President Estrada, procuring a ₱15 million check, which her brother encashed for personal use.
- Motion to Quash and Sandiganbayan Resolutions
- Petitioner moved to quash, arguing the Sandiganbayan lacks jurisdiction over estafa (Title X, RPC) and that she was not a public officer nor acted in relation to her office; claimed funds came personally from Estrada.
- The Sandiganbayan, Fifth Division, denied the motion (November 14, 2003) and the motion for reconsideration (February 4, 2004), holding jurisdiction under Section 4(A)(1)(g) and 4(b) of P.D. 1606 (as amended by R.A. 8249) and that source of funds is a trial defense.
Issues:
- Whether the Sandiganbayan has jurisdiction over the crime of estafa committed by petitioner.
- Whether Hannah Eunice D. Serana, as UP Student Regent, qualifies as a public officer under P.D. 1606, as amended.
- Whether the offense was committed in relation to petitioner’s official functions.
- Whether the ₱15 million allegedly came from the government coffers or private funds of President Estrada.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)