Title
Spouses Cajigas vs. People
Case
G.R. No. 156541
Decision Date
Feb 23, 2009
A woman is convicted of two counts of estafa for issuing postdated checks without sufficient funds, while her husband is acquitted due to lack of evidence, resulting in a sentence of reclusion perpetua for the woman and an order to pay the value of the checks.
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Case Digest (G.R. No. 156541)

Facts:

  • Petitioners: Luz Cajigas and Larry Cajigas.
  • Case: Spouses Cajigas vs. People, G.R. No. 156541.
  • Charges: Estafa under Article 315, paragraph 2 (d) of the Revised Penal Code, amended by Presidential Decree No. 818.
  • Location: Ozamiz City, Philippines.
  • Dates of alleged offenses: September 2 and October 14, 1989.
  • Key event: Issuance of postdated checks to Daisy Fuentes, a businesswoman.
  • Total amount of checks: P88,758.21 for jewelry purchases.
  • Outcome: Checks dishonored due to insufficient funds; petitioners had closed their bank accounts.
  • Trial Court: Found both petitioners guilty; Luz sentenced to reclusion perpetua and both ordered to indemnify Daisy Fuentes.
  • Court of Appeals: Upheld the trial court's decision but modified penalties.
  • Luz's defense: Claimed to have replaced dishonored checks with pawn tickets, which was disputed by Daisy Fuentes.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court partially granted the petition.
  • Luz Cajigas: Guilt affirmed for two counts of estafa; sentenced to an indeterminate penalty of six years and one day of prision mayor (minimum) to twenty-one years of reclusion perpetua (maximum) for Criminal Case No. RTC-1411, and six years and one day of prision mayor (minimum) to twenty-three years of reclusi...(Unlock)

Ratio:

  • The Court found sufficient evidence of Luz's guilt; she admitted to issuing the checks and assured Daisy Fuentes they were funded.
  • Essential elements of estafa were present: checks issued for obligations, insufficient funds, and damages incurred by Daisy.
  • Luz's claim of replacing dishonored checks with pawn tic...continue reading

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