Case Summary (G.R. No. 132848-49)
Background and Charges
On May 6, 1993, Aniceta Aquino along with Primitiva S. Dizon and Liberty Martinez was charged with the crime of Estafa under Article 315, paragraph 2 (d) of the Revised Penal Code. The allegation centered on a transaction that occurred on December 22, 1991, where the accused collectively purportedly deceived complainant Marie Antoinette Dacuma by receiving 400 sacks of rice valued at P200,000. They issued postdated checks in payment despite knowing that they lacked sufficient funds to cover these checks.
Trial Proceedings and Initial Ruling
During the trial, Aniceta Aquino was the only defendant present; her co-accused remained at large, with reports suggesting one may have died. The prosecution’s presentation included the testimony of Marie Antoinette Dacuma and documentary evidence, including the dishonored checks. The RTC, in its decision dated August 18, 1997, found Aquino guilty beyond a reasonable doubt, determining that she acted as a co-principal in the crime.
Appellate Claims
In her appeal, Aniceta Aquino contested the RTC's decision, asserting that the evidence presented was insufficient to warrant a conviction. The defense contended that her involvement was limited to facilitating the meeting between Dacuma and her co-accused and that mere presence did not equate to conspiratorial intent.
Legal Standards for Conspiracy
The court reiterated the legal framework surrounding conspiracy. A conspiracy occurs when two or more individuals unite in purpose and intent to commit a crime, underscoring the requirement that such an agreement must be proven with evidence beyond a reasonable doubt, analogous to the proof necessary for the underlying crime itself.
Evaluation of Evidence
The appellate court reviewed the prosecution's evidence and scrutinized whether the elements of conspiracy were established regarding Aniceta Aquino. It opined that there was insufficient evidence demonstrating that Aquino had the requisite knowledge of her co-defendants’ intentions to defraud Dacuma. The presumption of guilt cannot be established merely from her
...continue readingCase Syllabus (G.R. No. 132848-49)
Case Citation
- G.R. No. 130742
- Date: July 18, 2000
- Court: Supreme Court of the Philippines
- Division: Third Division
- Reporter Citation: 390 Phil. 1176
Parties Involved
- Plaintiff-Appellee: People of the Philippines
- Accused: Aniceta Aquino (alias "Annie"), Primitiva Dizon, Liberty Martinez
Nature of the Case
- The case involves an appeal from the Regional Trial Court (RTC) of Kalookan City, which found Aniceta Aquino guilty of estafa under Article 315 paragraph 2 (d) of the Revised Penal Code.
Background of the Case
- Date of Incident: December 22, 1991
- Complainant: Marie Antoinette Dacuma
- Allegations Against Accused: Conspiracy to defraud the complainant by issuing checks without sufficient funds in exchange for 400 sacks of rice valued at P200,000.00.
Procedural History
- The RTC decision dated August 18, 1997, led to the conviction of Aniceta Aquino as a co-principal in the crime of estafa.
- Only Aniceta Aquino was arrested; her co-accused remained at large, with unverified reports regarding Liberty Martinez's death.
Charges Filed
- The formal charge against the accused included:
- Conspiracy to defraud through the issuance of postdated checks despite knowing the accounts were closed, leading to damage to the complainant.
Evidence Presented
Prosecution's Evidence:
- Testimony of the complainant, Marie Antoinette Dacuma.
- Four postdated checks issued by Primitiva Dizon a