Case Summary (G.R. No. 175836)
Criminal Charge and Information
On September 20, 1990, Mila G. Pangilinan was accused of committing Estafa through false pretenses involving a stereo component. The information detailed that the accused misrepresented herself as having authority from Mr. Rodolfo Elnar to retrieve the stereo component and accessories from a minor, Luzviminda SJ Elnar, which she ultimately took unlawfully.
Proceedings in the Regional Trial Court
Mila Pangilinan was arraigned on March 12, 1991, and pleaded not guilty. Following the trial, the Regional Trial Court issued a decision on October 7, 1992, convicting her of Estafa under Article 315 of the Revised Penal Code and sentencing her to imprisonment and a fine.
Appeal and Decision by the Court of Appeals
Dissatisfied with the ruling, Pangilinan appealed to the Court of Appeals, which, on August 13, 1993, confirmed the trial court's conviction but modified the sentence to a lesser penalty of four months of arresto mayor and a fine of P17,450, with subsidiary imprisonment for insolvency. A motion for reconsideration and a subsequent petition for a new trial were denied.
Grounds for Review on Certiorari
Pangilinan filed a petition for review on certiorari based on two primary arguments: first, that the conviction was null and void due to lack of jurisdiction of the trial court over the charged crime; and second, alternatively, that guilt was not proven beyond a reasonable doubt.
Jurisdictional Analysis
Upon reviewing the case records, the court found merit in the argument pertaining to lack of jurisdiction. The information filed against Pangilinan did not specify the particular article of the Revised Penal Code violated. The trial court presumed the offense to fall under Article 315 but failed to include all necessary elements outlined for such a classification, particularly the aspect of demand from the offended party.
Legal Framework and Jurisdiction
According to Batas Pambansa Blg. 129, this crime fell within the exclusive original jurisdiction of the Municipal Trial Court, as it was punishable by a penalty not exceeding four years and two months. It was determined that the Regional Trial Court improperly assumed jurisdiction over the case.
Estoppel and Jurisdiction
The Office of the Solicitor General argued that Pangilinan was barred from contesting the issue of jurisdiction. However, the court clarified that jurisdiction can be questioned at any stage of the proceedings. The court distinguished that estoppel does not apply when the lower court lacked jurisdiction.
...continue readingCase Syllabus (G.R. No. 175836)
Case Overview
- The case involves Mila G. Pangilinan, the petitioner, who was convicted of the crime of Estafa by the Regional Trial Court (RTC) of Morong, Rizal.
- The conviction was based on an information that allegedly fell within the jurisdiction of the Municipal Trial Court (MTC).
- The Supreme Court reviewed the case on the grounds of lack of jurisdiction and insufficiency of evidence.
Background of the Case
- On September 20, 1990, Mila G. Pangilinan was charged with Estafa, under an information detailing her alleged actions of deceit.
- The accusation included misrepresenting herself as having been authorized by Mr. Rodolfo Elnar to collect stereo components from the Elnar household.
- The alleged crime occurred on June 15, 1984, in Tanay, Rizal, with the total value of the items being P17,450.00.
Proceedings in Lower Courts
- Pangilinan was arraigned on March 12, 1991, in the RTC where she pleaded "not guilty."
- After trial, the RTC convicted her on October 7, 1992, citing Article 315 of the Revised Penal Code (RPC) as the basis for the conviction.
- The Court of Appeals affirmed the conviction on August 13, 1993, modifying the sentence to four months of arresto mayor and a fine of P17,450.00.