Case Digest (G.R. No. 202264)
Case Digest (G.R. No. 202264)
Facts:
Alex Sulit y Trinidad, G.R. No. 202264, October 16, 2019, Supreme Court Second Division, Reyes, J., writing for the Court. The petitioner is Alex Sulit y Trinidad; the respondent is the People of the Philippines. Co-accused in the underlying prosecutions were Edgar G. Santias and George Gan; the complaints arose from investment transactions involving Valbury Assets Ltd. (Valbury).Nine criminal Informations (docketed as Criminal Cases Nos. 03-3663 to 03-3670 and 06-361) charged petitioner and Santias with estafa under Article 315(2)(a) of the Revised Penal Code for inducing several private complainants to invest with Valbury by false representations promising guaranteed profits and immediate withdrawal. Upon arraignment petitioner pleaded not guilty; Santias remained at large. During trial, private complainants Caridad Bueno, Ma. Lita Bonsol, and Gregoria Ilot testified that they were introduced to Valbury and to the accused, were assured of high returns, invested specified sums (including conversions to U.S. dollars), and later failed to recover promised profits or principal. The Securities and Exchange Commission certified that Valbury was not registered or authorized to buy and sell foreign currencies.
At trial the defense filed a demurrer to evidence; the trial court partly granted it and dismissed six of nine complaints for failure of some complainants to appear. The defense thereafter opted not to present evidence. In a Decision dated July 23, 2009, the Regional Trial Court (RTC), Branch 134, Makati City, found petitioner guilty beyond reasonable doubt of estafa under Article 315, par. 2(a), sentenced him under the Indeterminate Sentence Law, and ordered civil indemnities to the private complainants. Petitioner appealed to the Court of Appeals (CA).
In a Decision dated May 24, 2011, the CA affirmed the RTC’s conviction, holding that the elements of estafa and conspiracy were proven. Petitioner filed motions for reconsideration and for new trial, substituted counsel, and the CA issued a Minute Resolution (July 7, 2011) and later a Resolution (January 12, 2012) denying reconsideration; a subsequent Resolution (April 2, 2012) denied the motion to reopen/new trial. Petitioner then filed a Petition for Review on Certiorari before the Supreme Court (Rule 45), challenging his conviction and alleging denial of due process. The Supreme Court resolved the petition by decision promulgated October 16, 2019.
Issues:
- Was petitioner’s guilt for estafa proven beyond reasonable doubt?
- Was petitioner deprived of due process when he did not present evidence at trial?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)