Title
Securities and Exchange Commission vs. Santos
Case
G.R. No. 195542
Decision Date
Mar 19, 2014
Investment consultant Santos facilitated unregistered securities sales for PIPC Corporation, violating the Securities Regulation Code, leading to Supreme Court indictment.

Case Summary (G.R. No. 195542)

Background Facts

In 2007, numerous complaints were lodged against PIPC Corporation after the primary perpetrator, Michael H.K. Liew, went missing, taking with him substantial amounts of investors' money. PIPC Corporation was believed to be engaging in investment programs promising high returns with low risk. Santos allegedly played a role in enticing individuals to invest by providing misleading information about the investment products of PIPC and its alleged affiliations with overseas entities.

Legal Proceedings

The SEC formally filed a complaint against Santos, along with other officers of PIPC, for violations, specifically referencing Section 28 of Republic Act No. 8799, the Securities Regulation Code (SRC). The complaint claimed that Santos, along with others, had engaged in the offer and sale of unregistered securities while not being duly authorized to do so as required by the SRC.

Santos’ Defense

Santos denied the allegations, asserting that she was not responsible for soliciting any investments and had merely provided information as a part of her employment duties. She claimed that the investments from Lorenzo and Sy were made directly to PIPC-BVI, not to her or PIPC Corporation. Santos contended that there was a lack of evidence to demonstrate that she violated the SRC, particularly arguing that she acted within the bounds of her employment without malicious intent or criminal malfeasance.

DOJ and Appellate Court Resolutions

The Department of Justice (DOJ) initially found probable cause against Santos for violations of the SRC but subsequently, after a petition for review, the Office of the Secretary of Justice overturned this decision, leading to her exclusion from prosecution. The Court of Appeals affirmed this resolution, noting that Santos did not engage in buying or selling securities or act as a broker or agent, as no evidence directly demonstrated her involvement in the sale process.

Supreme Court Decision

The Supreme Court reviewed the case, emphasizing the broad discretion of prosecuting officials in determining probable cause during preliminary investigations. The Court ultimately ruled that the evidence suggested Santos had enticed complain

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