Case Summary (G.R. No. 180016)
Information, Plea, and Trial
An Information charged estafa (misappropriation in breach of trust) under Art. 315(1)(b) RPC for failure to deliver proceeds or return entrusted property. Corpuz pleaded not guilty and testified that he had no engagement with Tangcoy, claiming the receipt was back-dated evidence of a loan obligation.
RTC and CA Rulings
The RTC found elements of estafa proved—receipt in trust, misappropriation, prejudice, and demand—and convicted Corpuz, imposing 4 years 2 months (prisión correccional, medium) to 14 years 8 months (reclusion temporal, minimum). The CA affirmed but modified the maximum to 8 years (prisión mayor) plus 1 year per extra ₱10,000, totaling 15 years, with the same minimum.
Petition for Review: Assigned Errors
Corpuz claimed (a) receipt photocopy violated best-evidence rule, (b) Information defective as it omitted return deadline and misstated date, (c) failure to prove demand element, and (d) inconsistent testimony left reasonable doubt, warranting strict construction.
Prosecution and Amici Arguments
The OSG urged waiver of evidentiary objections (none at trial), sufficiency of Information by statute, and proof of oral demand by complainant’s queries. Amici debated modern inflation’s effect on penalties, urging legislative reform rather than judicial adjustment.
Waiver of Objections and Information Sufficiency
The SC held Corpuz waived any best-evidence rule objection by failing to object at trial or in comment. The Information met Rule 110 requirements: statutory designation, acts constitutive, name of offended party, approximate time (“on or about July 5, 1991”), and place. Time need not be exact if not material.
Proof of Estafa Elements
Complainant’s uncontradicted testimony showed: (1) delivery of jewelry in trust/commission; (2) misappropriation by non-return or non-remit; (3) prejudice of ₱98,000; and (4) oral demand (“Where are the items?”). Formal written demand unnecessary. Petitioner’s contradictory defense failed to raise reasonable doubt.
Credibility and Standard of Review
The SC accorded deference to RTC’s credibility findings, affirmed by CA, noting trial judges’ opportunity to observe witnesses. The equipoise rule did not apply: testimony quality outweighed numerical balance.
Penalty Range and Legislative
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Case Citation and Procedural History
• Supreme Court En Banc decision in G.R. No. 180016, promulgated April 29, 2014, reported at 734 Phil. 353.
• Petitioner Lito Corpuz filed a Petition for Review on Certiorari under Rule 45 seeking to reverse the CA’s March 22, 2007 Decision and September 5, 2007 Resolution.
• The CA affirmed with modification the RTC’s July 30, 2004 conviction of petitioner for estafa under Article 315(1)(b) RPC.
Antecedent Facts
• Petitioner and private complainant Danilo Tangcoy met at Admiral Royale Casino in Olongapo City in 1990.
• On May 2, 1991, Tangcoy delivered to Corpuz on commission basis—per written receipt—jewelry valued at ₱98,000, with agreement that proceeds be remitted or items returned within 60 days.
• The period lapsed without remittance or return; repeated demands failed.
• An Information was filed charging Corpuz with estafa, alleging misappropriation of ₱98,000 in jewelry entrusted under Article 315(1)(b) RPC.
Trial Proceedings
• January 28, 1992: Corpuz pleaded not guilty with assistance of counsel.
• Prosecution presented the sole testimony of Danilo Tangcoy and documentary receipt marked Exhibit A–A.
• Defense presented petitioner’s testimony alleging lender–collector relationship and that receipt was a blank form later misdated.
RTC Decision (July 30, 2004)
• Found petitioner guilty beyond reasonable doubt of estafa under Article 315(1)(b) RPC.
• Imposed indeterminate penalty under the Indeterminate Sentence Law:
• Minimum – 4 years and 2 months, prision correccional (medium).
• Maximum – 14 years and 8 months, reclusion temporal (minimum).
• Ordered indemnity of ₱98,000 as actual damages to Tangcoy and costs of suit.