Case Summary (G.R. No. L-41054)
Procedural History
The petition arises from a decision made by the Court of Appeals in CA-G.R. No. SP-03877, which reversed the order of the City Court of Manila and granted Hayco's petition for prohibition concerning the prosecution of seventy-five cases of estafa.
Allegations of Estafa
On January 5, 1973, the Units Optical Supply Company filed 124 complaints of estafa against Hayco under Article 315, para. 1-b of the Revised Penal Code. These complaints involved allegations of misappropriation where Hayco was accused of collecting sums from customers, neglecting to account for those amounts, and depositing them into his own bank accounts.
Civil Actions and General Power of Attorney
Concurrently, Lu Chiong Sun, the owner of the optical supply company, filed a civil action against Hayco, accusing him of misleading Sun into signing a general power of attorney while Sun was incapacitated. This alleged fraud facilitated Hayco's unauthorized management of the company's financial accounts.
Initial Legal Proceedings
Hayco initiated a petition for prohibition, arguing the frivolous nature of the seventy-five criminal cases against him and claiming they arose from a unified criminal intent. The City Court dismissed his petition, asserting that the separate deposits and withdrawals were distinct acts leading to independent charges of estafa.
Court of Appeals Ruling
The Court of Appeals reversed the lower court's ruling, creating a precedent that the series of alleged acts constituted a singular crime of estafa due to a single intent to defraud. This interpretation was based on the notion that all the actions were part of an overarching scheme of deceit against the employer.
Analysis of Plurality of Crimes
The Supreme Court examined the principle of plurality of crimes as defined in Article 48 of the Revised Penal Code. It clarified the distinction between “real plurality” and “ideal plurality,” noting that “real plurality” involves distinctly separate criminal acts while “ideal plurality” concerns situations where a single act results in multiple infractions.
Definition of Continuous Crime
Additionally, it was noted that the concept of a “continuous crime” pertains to instances where there exist multiple acts stemming from a single criminal intent. The Court found that Hayco's separate instances of misappropriation did not reflect a unified intent across the time frame, thereby qualifying each act as independent.
Legal Interpretation of Estafa
Moreover, the Court clarified that in the context of estafa as asserted under Article 315, para. 1-b of the Revised Penal Code, the element of fraud wa
...continue readingCase Syllabus (G.R. No. L-41054)
Case Overview
- This case involves a petition for review on certiorari of the judgment of the Court of Appeals in CA-G.R. No. SP-03877, promulgated on July 17, 1975.
- The central issues pertain to the proper appreciation of the rule on plurality of crimes (concursus delictuorum) and the concept of continuous crime.
Parties Involved
- Petitioners: Jose L. Gamboa and Units Optical Supply Company
- Respondents: Court of Appeals and Benjamin Lu Hayco (the private respondent)
Background of the Case
- Benjamin Lu Hayco was a former employee of Units Optical Supply Company in Sta. Cruz, Manila.
- On January 5, 1973, the company filed 124 complaints of estafa against him with the Office of the City Fiscal of Manila, leading to 75 cases being filed in court.
- The accusations involved misappropriation of funds collected from customers, which Hayco was obligated to account for.
- Lu Chiong Sun, the owner of the company, also filed a civil action against Hayco, alleging that he fraudulently obtained a general power of attorney to manage the company’s affairs during Sun's hospitalization.
Procedural History
- Hayco filed a petition for prohibition with preliminary injunction against the petitioners, claiming that the prosecution of the 75 estafa cases was oppressive and lacked jurisdiction.
- The lower court dismissed Hayco's petition, concluding that the acts complained of did not arise from a single criminal impulse.
- Hayco appealed to the Court of Appeals, which reversed the lower court's order, leading to the curre