Case Summary (G.R. No. 77569)
Procedural Background
On August 14, 1981, the First Assistant Provincial Fiscal of Laguna filed the information for estafa against the Celino brothers in the Court of First Instance of Laguna. The information detailed allegations of fraud through deceitful pretenses, aiming to mislead the complainant into believing in the existence of hidden treasures, which resulted in the payment of P50,230.00 by the complainant to the accused. Only Ricardo Celino faced trial, as the case against his brother Zosimo was dismissed posthumously. On May 29, 1985, the trial court found Ricardo guilty and sentenced him to imprisonment and restitution.
Factual Overview
The prosecution's case hinged on the testimonies of Jose Tan Kapoe and several witnesses, including Feliciano Batitis and Ricardo dela Cruz. Kapoe's account detailed how he was misled by the accused into believing that treasures buried beneath his property could be retrieved through a process he was obligated to pay for, with payments made over several occasions culminating in the total sum of P50,230.00. The method employed by the accused included deceptive practices, which involved hoaxes such as claiming instructions from a spiritual being purported to direct the digging process.
Defense Presentation
In response, the defense presented the testimonies of Ricardo Celino and Gualberto Libres. Ricardo claimed ignorance of any monetary transactions involving Kapoe and suggested that any payments made were connected to his deceased son Zosimo without his knowledge. Libres confirmed that at no point was Ricardo involved in discussions regarding the alleged treasure. The defense's position sought to portray the situation as a misunderstanding rather than a criminal conspiracy.
Appellate Review
Upon appeal, the Court of Appeals reviewed the trial court's findings and affirmed the conviction, determining that there was sufficient evidence to establish guilt beyond reasonable doubt. The appellate court rejected the argument that the transactions were mere joint ventures, reaffirming that the actions of the Celino brothers amounted to swindling as codified in Article 315 of the Revised Penal Code. The court cited their use of false pretenses to exploit the complainant's trust and gullibility.
Legal Principles Applied
The Court of Appeals upheld that the elements of estafa under Article 315 were met, emphasizing the fraudulent nature of the representations made by Ricardo and Zosimo Celino. These included pretending to possess supernatural abilities to locate hidden treasures, which constituted dec
...continue readingCase Syllabus (G.R. No. 77569)
Case Background
- The case originated from an information filed by the First Assistant Provincial Fiscal of Laguna on August 14, 1981, against the accused: Zosimo Celino, Ricardo Celino, and Requerido Celino for the crime of estafa.
- The alleged crime occurred on or about March 17, 1978, in Brgy. San Nicolas, Bay, Laguna, where the accused purportedly conspired to defraud complainant Jose Tan Kapoe by falsely claiming the existence of hidden treasures in his yard.
- The accused allegedly induced Tan Kapoe to pay a total of P50,230.00 under the pretense that this money was necessary to recover the supposed treasures.
Trial Proceedings
- During the arraignment, Ricardo and Zosimo Celino pleaded not guilty, while Requerido Celino remained at large.
- Zosimo Celino died on June 11, 1983, leading to the dismissal of the case against him on July 20, 1983.
- The trial court found Ricardo Celino guilty on May 29, 1985, and sentenced him to imprisonment ranging from two years, eleven months, and ten days to eight years of prision mayor, in addition to ordering him to return P41,300.00 to Tan Kapoe.
Prosecution's Evidence
- Complainant Jose Tan Kapoe testified that the accused approached him claiming there was a hidden treasure beneath his property, facilitated by instructions from a "dwarf."
- Throughout the engagement,