Case Summary (G.R. No. 143581)
Applicable Law and Constitutional Standard
Criminal offense charged: unjust vexation under Article 287, paragraph 2 of the Revised Penal Code (as invoked by the information). Constitutional requirement: Article VIII, Section 14 of the 1987 Constitution — no court decision shall be rendered without clearly and distinctly stating the facts and the law on which it is based. Procedural requirement: Rule 120, Section 2 of the 1985 Rules of Criminal Procedure (as amended) — judgments must be personally and directly prepared by the judge, in the official language, and must contain a clear statement of facts proved or admitted and the law upon which the judgment is based. Civil-law references used in damages analysis: Article 2217 (moral damages) and Article 2230 (exemplary damages) of the Civil Code.
Relevant Dates and Case Progression
Factual incident occurred on April 24, 1990. Information was filed on January 31, 1991, in the Municipal Trial Court (MTC), Bacolod City. The MTC rendered judgment on September 1, 1992. The Regional Trial Court (RTC), Bacolod City, issued a decision on December 8, 1992, adopting the MTC decision in toto. The Court of Appeals (CA) affirmed on August 16, 1993. The petitioner elevated the case to the Supreme Court by petition for review filed January 14, 1994; the Supreme Court ultimately addressed the matter on the merits.
Facts Found by the Courts
Petitioner admitted ordering the relocation/cutting of the electric, telephone, and water lines because the lines crossed his property line. Petitioner failed to present any permit or authorization from appropriate authorities allowing him to cut or relocate those service lines. The interruption of services was timed during the complainant’s business peak hours, causing interruption of business operations.
Municipal Trial Court Findings and Orders
The MTC found petitioner guilty beyond reasonable doubt of unjust vexation under Article 287(2) and sentenced him to “imprisonment for twenty days” (terminology later noted as erroneous; the proper term under the Revised Penal Code would be arresto menor). The trial court awarded moral damages (P10,000), exemplary damages (P5,000), attorney’s fees (P5,000), and costs, reasoning that the abrupt cutting of utilities during peak business hours unjustly disrupted the complainant’s operations and caused injury to her.
Regional Trial Court Decision and Its Defects
The RTC, in a decision that simply quoted the MTC decision in full and added two short paragraphs stating that the parties were required to file memoranda and that the RTC found “no ground to modify, reverse or alter the above-stated decision,” effectively adopted the lower court’s decision in toto without articulating its own findings of fact and conclusions of law. Such peremptory adoption failed to satisfy Article VIII, Section 14 of the 1987 Constitution and Rule 120, Section 2, which require that a court’s judgment clearly and distinctly state the facts proved or admitted and the law upon which the judgment is based. The Supreme Court characterized that form of decision writing as a nullity, citing controlling jurisprudence that memorandum decisions or peremptory affirmances that merely echo the lower court are inadequate (see Yao v. Court of Appeals and Francisco v. Permskul as referenced).
Court of Appeals Action and Supreme Court’s Observations
The Court of Appeals affirmed the RTC’s decision, but the Supreme Court observed that the RTC’s peremptory disposition was null and that the CA’s affirmance occurred without noting such nullity. Under the constitutional and procedural rules, an appellate or reviewing court must base its judgment on its own findings and reasoning rather than merely ratifying a lower court’s work that does not meet the statutory and constitutional content requirements.
Supreme Court’s Decision to Reach the Merits
Although the RTC decision was a nullity and could have led to remand for compliance with decision-writing requirements, the Supreme Court exercised its discretion to review the evidence and decide the case on the merits given the lengthy pendency of the matter. The Court reviewed the factual admissions and the record: petitioner’s admission of ordering the cutting/relocation; absence of any permit or authorization; and the timing of the interruption during peak business hours.
Determination of Criminal Liability
On the substantive issue of unjust vexation, the Supreme Court found that petitioner’s acts constituted unjust annoyance or vexation of the complainant. The combination of petitioner’s admission, lack of authority to cut or relocate utility lines, and the deliberate timing that interrupted the complainant’s business operations established guilt beyond reasonable doubt for the offense charged under Article 287(2) of the Revised Penal Code.
Analysis and Deletion of Damage Awards
The Supreme Court addressed the civil-damage awards separately. Moral damages under Article 2217 of the Civil Code are recoverable when they are the proximate result of a defendant’s wrongful act or omission; exemplary damages under Article 2230 require proof that the crime was committed with one or more aggravating circumstances justifying such punitive r
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Procedural History
- Information for unjust vexation filed by Assistant City Prosecutor Andres M. Bayona of Bacolod with the Municipal Trial Court, Bacolod City on January 31, 1991 (Crim. Case No. 48294).
- Municipal Trial Court, Bacolod City rendered a decision on September 1, 1992 finding Ong Chiu Kwan guilty beyond reasonable doubt of unjust vexation (Article 287 par. 2, Revised Penal Code) and sentenced him to "imprisonment for twenty days" and ordered various damages and fees.
- Regional Trial Court, Bacolod City, on December 8, 1992, adopted the Municipal Trial Court decision "in toto" without stating reasons.
- By petition for review on April 22, 1993, Ong Chiu Kwan elevated the case to the Court of Appeals (docketed as CA-G.R. CR No. 14209).
- The Court of Appeals promulgated its decision dismissing the appeal on August 16, 1993, agreeing with the lower courts' finding of guilt.
- A petition for review to the Supreme Court was filed on January 14, 1994; the Supreme Court gave due course to the petition on March 1, 2000.
- The Supreme Court, through a decision dated November 23, 2000 (G.R. No. 113006), reviewed the case and issued its disposition.
Facts
- On April 24, 1990, at around 10:00 in the morning, petitioner Ong Chiu Kwan ordered Wilfredo Infante to "relocate" (i.e., cut) the telephone, electric and water lines servicing the business establishment "Crazy Feet," owned and operated by Mildred Ong, because the lines "posed as a disturbance."
- Petitioner failed to present any permit or authorization from appropriate authorities to cut or relocate the electric wires, water pipe and telephone lines of the business establishment.
- The cutting of those utility lines interrupted the business operations of "Crazy Feet" during peak hours, to the detriment of its owner, Mildred Ong.
- Petitioner admitted having ordered the cutting because the lines crossed his property line.
Charge and Conviction by the Municipal Trial Court
- Charge: Unjust vexation under Article 287 par. 2 of the Revised Penal Code.
- Municipal Trial Court finding (September 1, 1992): Petitioner guilty beyond reasonable doubt.
- Sentence and awards imposed by trial court:
- "Imprisonment for twenty (20) days" (noted in the record to be an incorrect terminology; the proper term under the Revised Penal Code should be "twenty days of arresto menor").
- P10,000.00 – moral damages.
- P5,000.00 – exemplary damages.
- P5,000.00 – attorney's fees.
- Costs of suit.
- Trial court’s rationale included that abrupt cutting of utilities caused interruption of business operations during peak hours and thereby harmed the complainant; exemplary damages were awarded "as a deterrent to the accused not to follow similar act in the future."
Regional Trial Court Action
- The Regional Trial Court, Bacolod City, in a decision dated December 8, 1992, "simplistically adopted the decision of the lower court in toto," adding only two paragraphs noting that memoranda were filed and that it found "no ground to modify, reverse or alter the above-stated decision and hereby affirms the decision of the lower court in toto."
- The Regional Trial Court did not state independent findings of fact or conclusions of law beyond quoting and affirming the lower court’s decision.
Court of Appeals Decision
- The Court of Appeals promulgated its decision on August 16, 1993, dismissing petitioner’s appeal and agreeing with the lower courts' finding that petitioner was guilty beyond reasonable doubt of unjust vexation (CA-G.R. CR No. 14209). The CA decision was authored by Justice Tayao-Jaguros, with Justices de Pano, Jr. and Isnani concurring (as cited).
Issues Presented to the Supreme Court
- Legality and sufficiency of the conviction for unjust vexation given petitioner’s admission and failure to show permit or authorization.
- Validity of the Regional Trial Court’s decision that merely adopted the lower court decision in toto without independently stating facts an