Case Summary (G.R. No. 246787)
Background Facts
The charge stemmed from a loan agreement wherein Caspillo lent PHP 300,000.00 to the Llonillos in March 2009 under a "sangla-tira" scheme, which allowed him to collect rental income from Unit H of their property as interest. The Llonillos reportedly assured Caspillo that the property had no prior encumbrances, contrary to the fact that it was mortgaged to different banks.
Proceedings and Decisions in Lower Courts
Following his investigation that revealed the property was indeed encumbered and that the Llonillos had entered into similar agreements with other individuals for the same unit, Caspillo filed a complaint for estafa. On December 9, 2015, the MeTC convicted the Llonillos of Other Deceits and sentenced them to six months of imprisonment, a fine, and ordered them to pay Caspillo PHP 300,000.00 in actual damages. This decision was upheld by the RTC and later by the CA.
Issues on Appeal
The petitioners claimed several errors regarding judicial proceedings, chiefly asserting that the Information was void due to lack of approval from the Chief Prosecutor, that the prosecution failed to establish the element of fraud as a requisite for estafa, and whether their civil liability could be adjudged in the same proceeding.
Court's Analysis of Jurisdiction and Conviction
The Supreme Court affirmed that the MeTC had jurisdiction over the case despite the alleged defect in the Information, citing precedents that declared such defects to be waivable and not affecting the trial court's authority.
The key point of law examined was whether the elements of fraud necessary for Other Deceits were established. The Court ruled that because Caspillo was aware that the property was mortgaged before entering into the agreement, there was no fraudulent misrepresentation when the Llonillos discussed the loan arrangement. Thus, the essential elements of deceit and damage required for conviction were absent.
Acquittal and Civil Liability
While the Llonillos were acquitted from criminal liability under Article 318 due to the absence of deceit, the Court determined that they could still be held civilly liable for the unpaid loan arising from their contractual obligations. The Court referenced Article 29 of the Civil Code, which permits the recovery of civil damages in case of acquittal based on reasonable doubt regarding criminal liability, allowing for a separate ruling on civil claims pertinent to the facts established in the criminal proceeding.
Ruling on C
...continue readingCase Syllabus (G.R. No. 246787)
Case Background and Procedural History
- Spouses Enrique and Marites Llonillo were charged with the crime of Other Deceits under Article 318 of the Revised Penal Code.
- The accusation centers on a sangla-tira loan arrangement with Pedro Joel Caspillo involving a PHP 300,000.00 loan and apartment unit H at 236 Aguho Street, Makati City.
- The spouses allegedly misrepresented the unit as free of encumbrances and assured rental collection rights to Caspillo, which was later found untrue.
- Initial rulings by the Metropolitan Trial Court, Regional Trial Court, and Court of Appeals convicted the spouses.
- The Supreme Court reviewed the case en banc upon petition for certiorari.
Facts and Transaction Details
- In March 2009, spouses Llonillo, through their agent Grace Pangan, offered a sangla-tira arrangement on apartment units, seeking loan lenders without existing liens.
- Caspillo lent PHP 300,000.00 based on representations that the unit was clear of mortgages and that he could collect rentals as interest.
- A Memorandum of Agreement (MOA) was executed acknowledging receipt of the loan but did not specify monthly rental interest as Caspillo occupied the unit initially.
- Subsequent discovery revealed the unit was encumbered by mortgages and had other sangla-tira agreements with different individuals.
- Caspillo could not collect rentals and the loan remained unpaid.
Arguments and Defense Position
- Spouses Llonillo denied fraudulent misrepresentations, stating mortgages existed but were unknown to Caspillo who negotiated solely with their agent.
- They claim that the transaction was a simple loan, not a deceitful scheme.
- Alleged payments to Caspillo were unsubstantiated.
- They challenged the validity of the Information filed on grounds of lack of prosecutorial authority.
Lower Courts’ Findings and Rulings
- MeTC convicted spouses for fraudulent deceit based on misrepresentation and multiple sangla-tira schemes involving the same unit.
- RTC and CA affirmed the conviction, sustaining findings that spouses legally defrauded Caspillo.
- The courts ordered imprisonment, fines, and payment of damages plus interest and attorney’s fees.
Issues on Petition
- Jurisdiction over the case and persons due to alleged defective Information lacking chief prosecutor approval.
- Whether spouses Llonillo are guilty beyond reasonable doubt of Other Deceits under Article 318, RPC.
- Legitimacy of adjudging civil liability in the same criminal case despite acquittal.
Supreme Court’s Rulings on Jurisdiction
- The defect in prosecutorial approval on the Information is a formal defect that was waived and did not affect jurisdiction.
- The MeTC had jurisdiction to hear, try, and decide the case.
Supreme Court’s Findings on Criminal Liability
- No fraudulent misrepresentation was made prior to or simultaneously with the execution of the MOA.
- Caspillo admitted awareness of mortgages on