Case Summary (G.R. No. 172142)

Case Overview

This case involves a Petition for Review by David B. Campanano, Jr. against the Decision of the Court of Appeals which reversed the Department of Justice (DOJ) Resolution dismissing the complaint filed by Jose Antonio A. Datuin for Incriminating Innocent Persons. The original complaint was filed following Datuin's conviction for Estafa related to a transaction with Seishin International Corporation.

• Petitioner: David B. Campanano, Jr. • Respondent: Jose Antonio A. Datuin • Court: Supreme Court of the Philippines • Date of Decision: October 17, 2007

Background Facts

• Conviction for Estafa: Datuin was convicted of Estafa on May 3, 1999, based on a complaint by Seishin International Corporation.
• Appeals: Datuin's appeals were dismissed, and the conviction became final on October 24, 2003.
• New Evidence Claim: Datuin later claimed newly discovered evidence (a cash voucher) which he argued exonerated him and filed a complaint against Campanano and Yasunobu Hirota for Incriminating Innocent Persons.

Legal Principles

Incriminating Innocent Persons (Article 363 of the Revised Penal Code)

• This provision penalizes acts that directly incriminate an innocent person without constituting perjury.

• Key Definitions:

• Incriminating Innocent Persons: Actions that falsely attribute a crime to someone without perjury.

• Elements Required to Prove the Offense:

1. The offender performs an act.
2. The act directly incriminates an innocent person.
3. The act does not amount to perjury.

Jurisdictional Issues

• Venue Importance: The venue where the complaint is filed is essential for jurisdiction.

• Relevant Provisions:

• Section 15(a) of Rule 110 of the Revised Rules on Criminal Procedure states that a criminal action should be instituted in the court where the offense occurred.

• Dismissal of Complaint: Datuin's complaint was dismissed by the Quezon City Prosecutor due to lack of jurisdiction since the alleged crime occurred in Pasig City.

Court's Findings

• Appellate Court's Error: The Court of Appeals incorrectly concluded that the Counter-Affidavit executed in Quezon City established jurisdiction for the City Prosecutor of Quezon City.

• Conclusion: The allegations in Datuin's complaint did not sufficiently indicate a probable cause for incrimination under Article 363.

Final Ruling

• The Supreme Court granted Campanano's petition, reversing the Court of Appeals’ Decision and reinstating the DOJ Resolution that dismissed Datuin's complaint.

• Outcome:

• The complaint for Incriminating Innocent Persons against Campanano was dismissed.

Key Takeaways

• Jurisdiction is Essential: The place of the alleged crime is crucial in determining th...continue reading

Case Syllabus (G.R. No. 172142)

Case Overview

• The case involves a Petition for Review by petitioner David B. Campanano, Jr. against respondent Jose Antonio A. Datuin.
• The decision being challenged is from the Court of Appeals dated December 9, 2005, which set aside an earlier resolution from the Department of Justice (DOJ) that dismissed Datuin's petition for review.
• The underlying issue arose from a complaint of Estafa filed by Seishin International Corporation, represented by Campanano.

Background of the Case

• Campanano, as president of Seishin International Corporation, filed a complaint for Estafa against Datuin, which led to Datuin's conviction by the Regional Trial Court of Pasig City on May 3, 1999.
• Datuin's conviction was upheld by the Court of Appeals and became final and executory on October 24, 2003.
• Datuin later claimed the original Estafa complaint was false, unfounded, and malicious, citing newly discovered evidence—a cash voucher proving payment for two roadrollers.

Datuin's Complaint for Incriminating Innocent Persons

• On August 28, 2003, Datuin filed a complaint for Incriminating Innocent Persons against Campanano and Yasunobu Hirota, alleging that they maliciously imputed a crime of Estafa to him.
• He provided a detailed affidavit claiming his innocence and the discovery of the cash voucher dated June 28, 1993.
• Datuin argued that the complaint filed...continue reading