Title
Dimat vs. People
Case
G.R. No. 181184
Decision Date
Jan 25, 2012
Mel Dimat convicted under Anti-Fencing Law for knowingly selling a stolen 1997 Nissan Safari, despite claiming good faith; discrepancies in engine/chassis numbers proved knowledge of theft.
stolen vehicle
engine number
chassis number
A

Case Summary (G.R. No. 181184)

Petitioner

Mel Dimat was charged with violation of the Anti-Fencing Law for buying and subsequently selling a 1997 Nissan Safari alleged to have been carnapped from Jose Mantequilla.

Respondent

The People of the Philippines prosecuted Dimat before the Manila Regional Trial Court and appealed to the Court of Appeals; the Supreme Court reviewed the CA decision on petition.

Key Dates

May 25, 1998 — carnapping of Mantequilla’s Nissan Safari.
December 2000 — Dimat allegedly bought the Nissan Safari from Manuel Tolentino and sold it to Sonia Delgado for P850,000.00.
March 7, 2001 — police stopped the vehicle, discovered it matched the stolen vehicle list, and recovered it.
July 20, 2005 — RTC conviction and sentence.
October 26, 2007 — Court of Appeals affirmed with modification of penalty.
January 25, 2012 — Supreme Court decision under review.

Applicable Law

Primary statute: Presidential Decree No. 1612 (Anti-Fencing Law). Applicable constitution for legal basis and review: the 1987 Philippine Constitution (decision date is 1990 or later). Relevant jurisprudence cited: Tan v. People and Mendoza v. People.

Charge and Case Posture

Dimat was charged with violation of the Anti-Fencing Law for dealing in an article (the Nissan Safari) taken by carnapping. The RTC convicted and imposed imprisonment and damages; the CA affirmed with penalty modification; the Supreme Court reviewed the CA decision.

Facts and Trial Evidence

  • Mantequilla owned a 1997 Nissan Safari (plate JHM-818), mortgaged to a bank, and reported it carnapped on May 25, 1998.
  • In December 2000, Sonia Delgado purchased from Dimat a 1997 Nissan Safari for P850,000.00; the deed of sale stated engine number TD42-126134 and chassis number CRGY60-YO3553.
  • On March 7, 2001, TMG officers stopped a Nissan Safari bearing a suspicious plate; inspection revealed engine number TD42-119136 and chassis number CRGY60-YO3111, which matched the vehicle reported stolen from Mantequilla. The police recovered the vehicle and traced it to the stolen list.
  • Dimat testified that he bought the vehicle in good faith from Tolentino, who allegedly showed an old certificate of registration and official receipt and promised replacement documents in Dimat’s name but failed to deliver. Dimat asserted he did not know Mantequilla and denied criminal intent. Delgado could not produce registration documents for her purchase.

Defense and Contentions

Dimat’s central defenses were: (1) he purchased the vehicle in good faith for value from Tolentino; (2) the deed of sale he possessed bore different engine and chassis numbers than those of the stolen vehicle, suggesting the vehicle he sold to Delgado was not the same as the stolen one; and (3) lack of knowledge and criminal intent.

Legal Issue Presented

Whether the Court of Appeals correctly ruled that Dimat knowingly sold the Nissan Safari that had been carnapped from Mantequilla — i.e., whether the elements of fencing under PD 1612 were established, notably knowledge (or constructive knowledge) that the vehicle was derived from theft or robbery and the intent to gain.

Elements of Fencing and Legal Standard

The Court reiterated the elements of the crime of fencing: (1) a robbery or theft has been committed; (2) the accused, not a participant in the original theft, bought, received, possessed, acquired, concealed, sold, disposed of, or otherwise dealt in the article taken; (3) the accused knows or should have known that the article was derived from the crime; and (4) the accused intends by the transaction to gain for himself or another (citing Tan v. People). The Court also observed that PD 1612 is a special law regarded as malum prohibitum, such that proof of criminal intent is not a requisite element in the same manner as common-law crimes, though the prosecution must still establish knowledge or that the accused should have known, and that the accused acted for gain (citing Mendoza v. People).

Application of Law to the Facts

  • Commission of theft: The record established carnapping of Mantequilla’s Nissan Safari on May 25, 1998.
  • Dealing in the stolen article: The vehicle recovered and inspected bore engine and chassis numbers corresponding to the stolen vehicle; that vehicle was sold by Dimat to Delgado in December 2000, satisfying the second element.
  • Knowledge or constructive knowledge: The Court found that the deeds of sale presented by Dimat contained engine and chassis numbers inconsistent with those physically observed on the vehicle, indicating the documents were inaccurate. Dimat’s claim that Tolentino showed existing registration documents was implausible because a carnapped vehicle would not have legitimate documents to show. Tolentino’s subsequent failure to deliver promised new documents further confirmed that the vehicle was improperly documented and likely derived from an illicit source. Despite being aware of the defective documentation and Tolentino’s failure to regularize papers, Dimat proceeded to sell the vehicle to Sonia Delgado. The Court concluded that these facts established that Dimat either knew or should have known the vehicle wa
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