Case Summary (G.R. No. 106539)
Jurisdiction and Applicable Law
This case is governed by the Revised Penal Code (RPC), particularly Article 318(1), which pertains to the crime of Other Deceits. The Metropolitan Trial Court (MeTC) and the Regional Trial Court (RTC) both handled the case, with the Court of Appeals affirming the decisions made by the lower courts. The primary issues relate to the guilt of Consolacion in committing fraud and whether the statutory elements of the alleged crime were sufficiently satisfied.
Facts of the Case
The prosecution filed charges against Consolacion and co-accused for defrauding multiple individuals through fraudulent misrepresentations regarding the sale of housing units in Ireneville IV Subdivision. The complainants provided substantial amounts as reservation fees and equity based on assertions that their housing loans would be automatically approved due to Consolacion’s alleged connections. However, upon moving in, the complainants experienced severe flooding and discovered significant issues with the development.
Trial Court Proceedings
Consolacion denied the accusations during her trial while invoking a motion for dismissal based on the claim that the case had prescribed, given the date of the alleged offense in 1985 and the complaint's filing in 2004. The MeTC dismissed the motion and proceeded to trial, ultimately finding her guilty of Other Deceits and imposing penalties including imprisonment and various damages. The court underscored the elements of deceit and the failure to disclose material facts regarding the nature of the subdivision.
Regional Trial Court Ruling
On appeal, the RTC affirmed the MeTC's conviction but modified it by deleting the award of moral damages. The RTC emphasized that the prescriptive period for prosecuting the crime began only upon discovery of the crime by the complainants in 2000, thus validating the timeliness of the filing in 2004. The RTC noted that the evidence of fraud, including false assurances made by Consolacion during the selling process, was sufficient to uphold the conviction.
Court of Appeals Decision
The CA upheld the lower courts' findings, agreeing that all essential elements of the crime existed in this case. It reiterated that the ongoing deceit committed by Consolacion resulted in the complainants suffering damages, leading to the conclusion that the crime of Other Deceits had been substantiated. The CA found that the jurisdiction of the MeTC was appropriate due to the crime's nature as a continuing offense and the actions taken within Quezon City.
Supreme Court Review and Decision
Upon review, the Supreme Court determined that the prosecution failed to prove all elements of the crime of Other Deceits beyond a reasonable doubt. The Court held that while the private respondents claimed that they were misled into purchasing units in a fl
...continue reading
Case Syllabus (G.R. No. 106539)
Overview of the Case
- This case involves a Petition for Review on Certiorari filed by Consolacion P. Marcos against the People of the Philippines and private respondents, concerning her conviction for the crime of Other Deceits under Article 318(1) of the Revised Penal Code (RPC).
- The petition was reviewed by the Supreme Court following decisions from the Court of Appeals and the Regional Trial Court, which upheld her conviction.
- The Supreme Court's ruling ultimately acquitted Consolacion, reversing the previous decisions.
Background and Facts of the Case
- On January 25, 2008, the Quezon City Assistant Prosecutor filed an Information for Other Deceits against Consolacion and others, alleging defraudment of several individuals through deceptive practices related to low-cost housing units.
- The alleged fraud occurred in February 1985, where the accused, including Consolacion, purportedly misled complainants regarding the sale of housing units located in Ireneville IV Subdivision, Biñan, Laguna.
- The complainants contended they were induced to pay reservation fees and equity based on false representations about automatic loan approvals and the actual conditions of the subdivision.
Procedural History
- Consolacion pleaded not guilty on April 1, 2008, while co-accused Molera and Santos were absent, and Leonilo Marcos was deceased.
- A motion to dismiss on grounds of prescription was denied by the trial court, which ruled that the crime was discovered only