Astadan, Angela

Morales, Lyn San Sebastian

Armentia, Rodolfo Jr. D

Cases Discussed

Horca vs. People G.R. No. 224316

Accused was charged with the crime of Theft. Trial Court convicted the accused. CA affirmed the
decision of the Trial Court. Supreme Court ACQUITTED the accused on the ground of reasonable doubt on the
accused’s intent to gain. The prosecution failed to adduce any concrete evidence which would show that the
accused had taken the cash for her own personal gain.

Vda de Manjares vs. People G.R. No. 207249

Accused was charged with the crime of ESTAFA committed with abuse of confidence through
conversion or misappropriation. RTC found the accused guilty. The CA affirmed the conviction in toto. The
Court ACQUITTED the accused on the ground that the first two elements of estafa was not established.
Accused only had material possession, and not juridical possession, of the goods delivered to her for sale. The
Court finds that the prosecution failed to establish the existence of misappropriation beyond reasonable
doubt.

Imperial vs. People G.R. No. 230519

Accused was charged with the crime of THEFT Qualified by Grave Abuse of Confidence. Trial Court
convicted the accused of the crime of Qualified Theft, as charged. The CA affirmed the conviction. The Court
ACQUITTED the accused on the ground of reasonable doubt. The CA committed grave abuse of discretion, as
its factual findings are not supported by the required quantum of evidence that is sufficient to sustain a
judgment of conviction. the prosecution failed to establish the corpus delicti of the crime of theft. Corpus
delicti, in its legal sense, refers to the fact of the commission of the crime charged or to the body or substance
of the crime. In the crime of theft, corpus delicti has two elements: 1) that personal property is lost by its
owner, and 2) that it was lost through felonious taking.

People vs. Sanota G.R. No. 2233659

Accused were charged with the crime of ROBBERY With Homicide. The RTC convicted the accused of
the crime charged. The CA Affirmed the conviction. The Court Affirmed the decision of the CA. The
prosecution's witnesses established the existence of circumstances that support a clear conclusion that the 3
accused conspired to commit robbery, that they carried out the plan and, as a result of such concerted
resolve, complainant's only son was shot and killed.
PEOPLE OF THE PHILIPPINES VS ROBERTO CAMPOS
G.R. No. 252212
Facts:
Emeliza together with her boyfriend and best friend Marilou was eating in the house when suddenly a man
came inside their house and took Emeliza’s cellphone. Emeliza shouted to stop the man with a gun from
taking her phone, but the man shoot her on the chest that cause her death.
The RTC and CA held Campos to be liable of Robbery with Homicide

Ruling:
The Elements of the crime Robbery with Homicide are; 1) the taking of personal property with violence or
intimidation against persons; (2) the property taken belongs to another; (3) the taking was done with animus
lucrandi, and (4) on the occasion of the robbery, or by reason thereof, homicide was committed.
Accused took the personal property with violence with the presence of a gun. The second element is that the
personal property belongs to Emeliza. The third element was it was done with intent to gain and the last
element was on the occasion of robbery the owner of the personal property was killed.
The Supreme Court held that in the instant case all the elements of the crime of robbery with homicide are
present.

CO VS PEOPLE
G.R. No. 233015
Facts:
Accused Luis L. Co. and Alvin Milton S. Co were President and Asst. Vice-President of Jade Progressive Savings
and Mortgage Bank. They were charged with the crime of Estafa.
Allegedly they issued payment amounting to P3,032,909.00, Philippine Currency for the services rendered by
ACME INVESTIGATION SERVICES. INC., a non-existent security agency,
To the damage and prejudice of Jade Progressive Savings and Mortgage Bank, its depositors, creditors and the
Bangko Sentral ng Pilipinas

Ruling:
The Supreme Court reversed the decision of the RTC and CA. The elements of Estafa were the following.
1. That the accused used a fictitious name or false pretense that he possesses power, influence, qualifications,
property, credit, agency, business, imaginary transaction, or other similar deceits.
2. that the accused used such deceitful means prior to or simultaneous with the execution of the fraud.
3. that the offended party relied on such deceitful means to part with his money or property.
4. that the offended party suffered damage.

In this case petitioner signed the billing statement and requested payment for ACME. Fraud was committed
because a billing statement was signed by the accused. The billing statement here was a private document.
The private document was being falsificied. The Supreme Court discussed that If the falsification of a private
document is committed as a means to commit estafa, the proper crime to be charged is falsification. If the
estafa can be committed without the necessity of falsifying a document, the proper crime to be charged is
estafa.
The issue on falsification was not established because the witness had no personal knowledge of the signing
of the private documents. Allegedly the signature of the officials of ACME were the same as the Accused-
Appellant.
Lacking all the elements of the crime of Estafa and Falsification of private documents the Supreme Court
Acquitted both accused.

DELA CRUZ VS PEOPLE

G.R. No. 236807

Facts:
Here in petitioner Conchita dela cruz was the owner of DEB repair shop and parts supply.
The alleged amount of P6,368,364.00 was for the 409 transactions purportedly for the emergency repairs of
39 DPWH service vehicles. The spare parts were supplied by accused- appellant.
Conspiring, confederating and mutually helping one another, with intent to defraud the government, did then
and there, willfully, unlawfully and feloniously forge and falsify or cause to be forged and falsified documents,
purportedly for emergency repairs of various DPWH vehicles and/or purchase of spare parts, with a total
amount of SIX MILLION THREE HUNDRED SIXTY-EIGHT THOUSAND THREE HUNDRED SIXTY¬-FOUR PESOS
(P6,368,364.00), and thereafter, cause the payment of said fictitious repairs and/or purchase of spare parts in
the said total amount from funds.
Held in Sandiganbayan the accused found guilty beyond reasonable doubt of complex crime of Estafa through
Falsification of Documents

Ruling:
The elements of estafa under Article 315 paragraph 2(a) of the RPC are the following:
1. That there must be a false pretense, fraudulent act or fraudulent means;
2. That such false pretense, fraudulent act or fraudulent means must be made or executed prior to or
simultaneously with the commission of the fraud;
3. That the offended party must have relied on the false pretense, fraudulent act, or fraudulent means, that is,
he was induced to part with his money or property because of the false pretense, fraudulent act or fraudulent
means; and
4. That as a result thereof, the offended party suffered damage.
First. There were false pretenses, fraudulent acts or fraudulent means in that it was made to appear, through
the use of the falsified documents, that the DPWH service vehicles in question underwent emergency repairs
that required purchases of spare parts, and that reimbursements were due to accused Martinez.
Second. The false pretenses, fraudulent acts or fraudulent means, in the form of falsification of documents,
were employed prior to the commission of the fraud; that is to deceive the government in paying the claims
for the fictitious emergency repairs/purchases of spare parts;
Third. The government was induced to pay the claims relying on false pretenses, fraudulent acts or fraudulent
means employed;
Fourth. The government suffered damages in the total amount of P5,166,539.00, the sum total of the false
claims paid.87 (Emphasis in the original.)
All the elements of the Crime of Estafa, in this case, were present.
In case of Valenzuela v. People, Aristotel Valenzuela and Jovy Calderon were sighted outside SM North EDSA
by security guard Lorenzo Lago, unloading cases of detergent Tide Ultramatic on an open parking space.
Valenzuela loaded the cartons of detergent while Calderon was looking into a taxi and procedeed to leave the
parking area. Lago stopped the cab, checked the cartons, and asked for a receipt but Valezuela and Calderon
reacted a fled-on foot. The same were apprehended on the scene and the stolen merchandise recovered was
worth P12,090.
RTC convicted both petitioner and Calderon of the crime of consummated theft and affirmed by the Court.
Court held that theft is produced when there is deprivation of personal property by one with intent to gain.
Thus, it is immaterial that the offender is able or unable to freely dispose the property stolen since he has
already committed all the acts of execution and the deprivation from the owner has already ensued from such
acts. Therefore, theft cannot have a frustrated stage, and can only be attempted or consummated.

In case of Del Rosario v. People, The RTC and CA convicted Edwin for the crime of robbery. Charlotte and Kim
Evangelista Casiano flagged down a jeepney. After boarding said jeepney, two male persons, who were later
identified to be Roxan and Edwin, also boarded the vehicle. Roxan snatched the necklace of Charlotte, both
disembarked from the jeepney, and ran away.
The Court charged the petitioners on the crime of theft and not robbery. the element of robbery is violence
against person or intimidation on person is lacking. the requisite of violence to obtain in cases of simple
robbery, the victim must have sustained less serious physical injuries or slight physical injuries in the occasion
of the robbery. The Court added that the fact that the necklace was "grabbed" did not automatically mean
that force attended the taking. The Court finds the argument to be a pure play of semantics that grab means
to take or seize by or as if by a sudden motion or grasp; to take hastily. Clearly, the same does not suggest the
presence of violence or physical force in the act; the connotation is on the suddenness of the act of taking or
seizing which cannot be readily equated with the employment of violence or physical force.

In the case of Arriola v. People, The RTC convicted accused Luis T. Arriola of Estafa under Section 315,
Paragraph 2(a) of the Revised Penal Code (RPC). On appeal, the CA affirmed the RTC Decision. The prosecution
alleged Ingeborg Del Rosario met accused Arriola, a real estate broker of real properties located in Tagaytay
City. At that time, Del Rosario had already bought a lot in Tagaytay City owned by one Ernesto Marcelo.
Arriola informed Del Rosario that the lot adjacent to Marcelo's land was also for sale. He showed her a letter
purportedly from the subject lot owner, Paciencia G. Candelaria authorizing him to sell it in her stead. Del
Rosario decided to buy Candelaria's lot and gave Arriola P100,000.00 as earnest money. Aside from the
Authorization Letter, Arriola also showed Del Rosario a certified copy of Transfer Certificate of Title (TCT)
proving that the lot was in Candelaria's name, and a fax transmittal from Candelaria, who allegedly was then
in Australia, authorizing Arriola to transact and receive the purchase price in her behalf. Del Rosario paid the
balance of the purchase price in the amount of P337,000.00. Del Rosario signed a Deed of Absolute Sale
prepared by Arriola and purportedly signed by Candelaria and one Sister Adela Arabia of the Order of St.
Benedict as her witness. However, accused Arriola failed to deliver the originals of the Deed and TCT to Del
Rosario.
Court Petitioner acquitted Arriola, for failure of the prosecution to prove his guilt beyond reasonable doubt, of
Twenty-One (21) counts of Falsification of Public Document.
Clearly, there is no direct evidence that links Arriola to the commission of the crime. As the RTC itself stated,
"although no eyewitness could particularly delineate the particular scheme or method used in the falsification
of subject CTCs, the vestiges of all alterations made thereon could only be pinned down to the public
accountability of accused Felix L. Arriola and his complicity with known fixer, identified as accused Ma.
Theresa Tabuzo." The RTC was, thus, compelled to rely solely on the following pieces of circumstantial
evidence which appeared to have been established to justify its finding of guilt. It could be that Arriola had
actually participated in the commission of the crime. The Court, however, cannot convict him when the
circumstantial evidence relied upon by the RTC and subscribed to by the CA is plainly inadequate and
unconvincing. Thus, it cannot be said that the prosecution was able to prove his guilt beyond reasonable
doubt.