Case Summary (G.R. No. 140904)
Case Background
The case originated from a purchase agreement for a paper bag-making machine by Zeny Alfonso from Solid Cement Corporation, which was allegedly compromised as the machine was already mortgaged to another creditor. Alfonso filed a criminal complaint after she was unable to receive the machine, despite prior arrangements. The City Prosecutor initially dismissed her complaint, asserting any liability was civil rather than criminal. However, the Department of Justice reversed this dismissal, leading to the filing of an Information for estafa in the MeTC.
Evidence and Procedural History
The prosecution's sole witness was Zeny Alfonso, who testified about the transaction and her inability to obtain the machine. The petitioners challenged the admissibility of the prosecution's evidence, which consisted mainly of photocopies of various documents relating to the sale. The MeTC denied the petitioners' demurrer to evidence, suggesting that there was a prima facie case against them based on the documents and Alphonso's testimony.
Regional Trial Court's Intervention
Following this, the petitioners sought relief from the Regional Trial Court, which found merit in their arguments and reversed the MeTC's decision, declaring the denial of the demurrer to evidence null and void. The RTC dismissed the criminal case, concluding that the evidence presented did not support a trial.
Court of Appeals Reversal
The People appealed to the Court of Appeals, which ruled in favor of reinstating the criminal case, asserting that the petitioners should have presented their evidence rather than opting for a petition for certiorari. The appellate court argued that the RTC’s dismissal did not equate to an acquittal and that the petitioners could not invoke the double jeopardy principle at this stage.
Legal Issues Raised
The petitioners contested the Court of Appeals' decision on several grounds, including:
- The appellate court's mischaracterization of the proper legal remedy following the denial of the demurrer to evidence.
- The assertion that the RTC's order constituted an acquittal, barring further prosecution under double jeopardy.
- The failure to accurately assess the prosecution's evidence and admissibility.
Supreme Court's Ruling
The Supreme Court ruled in favor of the petitioners, emphasizing that the evidence presented by the prosecution was inadmissible due to the lack of authentication of the photocopies. The Court outlined the requirements of Rule 132 pertaining to the admissibility
...continue readingCase Syllabus (G.R. No. 140904)
Case Background
- The case involves a petition for certiorari and prohibition with a request for a writ of preliminary injunction filed by petitioners Rene S. Ong, Magdaleno B. Albarracin, Jr., Petronio C. Aaliwin, and J. O. Nerit.
- Petitioners were accused of estafa and other deceit before the Metropolitan Trial Court (MeTC) of Makati City.
- The genesis of the case traces back to a transaction on February 8, 1993, where Zeny Alfonso purchased a paper bag-making machine for P362,000 from Solid Cement Corporation.
Facts of the Case
- Zeny Alfonso's attempt to claim the purchased machine was thwarted by the discovery that the machine had been previously mortgaged to another creditor, who refused to release it.
- After offering to refund Mrs. Alfonso, she opted instead to file a criminal complaint with the City Prosecutor of Makati, which was initially dismissed, but later reversed by the Department of Justice.
- On October 18, 1994, an Information for estafa was filed against the petitioners.
- During the trial, the prosecution relied solely on the testimony of Zeny Alfonso and documentary evidence, which petitioners contested as inadmissible.
Procedural History
- Petitioners filed a demurrer to evidence, asserting that the documentary evidence was composed of unauthenticated photocopies and thus inadmissible.
- The MeTC denied the demurrer, asserting that there was a prima facie case against the petitioners.
- The Regional Trial Court (RTC) later reversed this decision, leading to a petition by the People to the Court of