Case Digest (G.R. No. 215132) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Isidro Dulay III and Elena Dulay v. People of the Philippines (G.R. No. 215132, September 13, 2021), petitioners Isidro and Elena Dulay purported in February 1999 to sell a 450-sqm lot in Baguio City to spouses Isabelo and Hilaria Dulos. They presented a photocopy of Transfer Certificate of Title (TCT) No. T-2135, falsely claiming identical identity with the registered owners, “Isidro and Virginia Dulay,” and asserting that the title was under reconstitution. The parties agreed on a ₱950,000 purchase price, paid a ₱150,000 down payment and monthly ₱30,000 installments. When the Dulos reached total payments of ₱707,000 without receiving a title, they discovered petitioners were neither the registered owners nor in the reconstitution process. The Dulos stopped paying and filed estafa charges under Article 315(2)(a) of the Revised Penal Code (RPC) in the Regional Trial Court (RTC) of Agoo, La Union, which denied petitioners’ motion to quash and convicted them in a Septem Case Digest (G.R. No. 215132) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Property
- Petitioners, spouses Isidro and Elena Dulay, represented themselves as the owners of a 450-sqm lot in Baguio City (TCT No. T-2135). They claimed that “Virginia” in the title was the same person as Elena.
- Complainants, spouses Isabelo and Hilaria Dulos, agreed to buy the lot for ₱950,000: ₱150,000 down and ₱30,000 monthly for two years. A receipt was issued on February 19, 1999.
- Payment, Discovery and Defense
- The Dulos paid a total of ₱707,000 but never received the title. Upon inquiry at the Registry of Deeds, they learned the true registered owners were different persons—Isidro Dulay’s uncle and his wife, Virginia, and their daughter Carmencita.
- Petitioners denied deceit. They asserted (a) the title was under reconstitution; (b) Isidro was adopted heir of the prior owner, Maria Dulay; and (c) a revoked donation clouded the title. They also filed a Motion to Quash, claiming the offense was under Art. 316(1), not Art. 315(2)(a) of the RPC.
- Lower Court Proceedings
- The RTC denied the Motion to Quash, found petitioners guilty of estafa by false pretenses (Art. 315(2)(a), RPC), and sentenced them to an indeterminate penalty of 4 years 2 months prision correccional (minimum) to 20 years reclusion temporal (maximum).
- The Court of Appeals affirmed with modification, adding 6% per annum interest on actual damages awarded from finality of decision until full payment.
Issues:
- Liability Despite Notice
- Are petitioners guilty of estafa when the Dulos were aware the title was not yet in petitioners’ names at the time of payment?
- Did the Dulos’ knowledge negate the element of deceit?
- Proper Offense Classification
- Should petitioners have been charged under Art. 316(1), RPC (lower penalty for pretending ownership of real property), instead of Art. 315(2)(a)?
- Does the doctrine of pro reo and rule of lenity favor application of the lesser offense?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)