Case Summary (G.R. No. 172142)
Procedural Background
The petition for review challenges the December 9, 2005 Decision of the Court of Appeals, which overturned an August 20, 2004 Resolution by the Department of Justice (DOJ) that dismissed Datuin’s petition for review. Datuin was initially convicted of estafa in 1999 by the Regional Trial Court (RTC) of Pasig City, with the decision upheld by the Court of Appeals and becoming final on October 24, 2003. Datuin later filed a complaint against Campanano for Incriminating Innocent Persons based on newly discovered evidence.
Respondent's Complaint Details
Datuin's complaint included a cash voucher he discovered, purportedly proving his payment for roadrollers sold by Seishin International Corporation, thus asserting that the estafa complaint was false. He claimed that the prosecution was malicious and unfounded, leading to his wrongful conviction.
Dismissal by the City Prosecutor
On January 20, 2004, the Quezon City Prosecutor's Office dismissed Datuin's complaint for lack of jurisdiction and merit, asserting that the estafa case was properly tried in Pasig City, where the offense occurred. The office noted that it had no jurisdiction over the allegations given the established merit of the original prosecution.
Department of Justice Resolutions
Datuin’s subsequent petition to the DOJ was dismissed, affirming the City Prosecutor's findings. The dismissal was based on the determination that no error warranted a reversal.
Court of Appeals Decision
The Court of Appeals later found errors in the DOJ's dismissal, claiming jurisdiction due to Campanano's counter-affidavit being executed in Quezon City and remanded the case for further investigation, which prompted the petition before the Supreme Court.
Supreme Court Analysis of Jurisdiction
The Supreme Court underscored that venue is crucial for jurisdiction in criminal cases, as defined under Section 15(a) of Rule 110 of the Revised Rules on Criminal Procedure, which necessitates that actions are instituted where the crime occurred. The Court concluded that Datuin’s complaint did not allege that the incriminating actions took place in Quezon City, thus asserting proper dismissal by the City Prosecutor.
Misinterpretation of Evidence
The Court further clarified that the allegations in Datuin’s affidavit did not satisfactorily establish probable cause for the offense of Incriminating Innocent Persons under Article 363 of the Revised Penal Code. The Court highlighted that this article punishes speci
...continue readingCase 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 by Campanano was baseless a