Corpuz vs People

G.R. No. 180016. April 29, 2014.

LITO CORPUZ, petitioner, vs. PEOPLE OF THE PHILIPPINES,

respondent

DOCTRINE: Statutory Construction; View that in case of doubt in the interpretation

or application of laws, it is presumed that the lawmaking body intended right
and justice to prevail.—Article 10 of the Civil Code states: “In case of doubt in
the interpretation or application of laws, it is presumed that the lawmaking body
intended right and justice to prevail.” The Code Commission found it necessary
to include this provision to “strengthen the determination of the Court to avoid
an injustice which may apparently be authorized in some way of interpreting the
law.”

PERALTA, J.:

FACTS:
1. Private complainant, Danilo Tangcoy and petitioner, Lito Corpuz, met at the Admiral
Royale Casino in Olongapo City sometime in 1990.
2. Tangcoy was then engaged in the business of lending money to casino players and
upon hearing that Tangcoy have some pieces of jewelry for sale, Corpuz approached
him on May 2,1991 at the same casino and offered to sell the said pieces of jewelry on
commission basis.
3. Tangcoy agreed, and as a consequence, he turned over to petitioner the following
items: an 18k diamond ring for men; a woman’s bracelet; one(1) men’s necklace and
another men’s bracelet, with an aggregate value of P98,000.00, as evidenced by
receipt of even date.
4. They both agreed that petitioner shall remit the proceeds of the sale, and/or. if unsold,
to return the same items, within a period of 60 days. The period expired without
petitioner remitting the proceeds of the sale or returning the pieces of jewelry. When
Tangcoy was able to meet petitioner, the latter promised the former that he will pay
the value of the said items entrusted to him, but to no avail.
5. A criminal complaint for estafa was filed against Corpuz.
6. On the prosecution, it was established that Tangcoy and Corpuz were collecting
agents of Antiono Balajudia, who is engaged in the financing business of extending
loans to base employees. For every collection made, they earn a commission.
Petitioner denied having transacted any business with Tangcoy.
7. However, he admitted obtaining a loan from Balajadia sometimes in 1989 for which
he was made to sign a blank receipt. he claimed that the saem receipt was then dated
May 2, 1991 and used as evidence against him for the supposed agreement to sell the
subject pieces of jewelry, which he did not even see.
8. Regional Trial Court and Court of Appeals accused Corpuz guilty of estafa.
 ISSUE/S:
1. Whether or not the RTC and CA erred in their ruling and that the punishement
was harsh

SUBJECT TO STATUTORY CONSTRUCTION:

ART. 315. Swindling (estafa). The elements of estafa with abuse of confidence are as
follows: (a) that money, goods or other personal property is received by the offender in trust,
or on commission, or for administration, or under any other obligation involving the duty to
make delivery of, or to return the same; (b) that there be misappropriation or conversion of
such money or property by the offender or denial on his part of such receipt; (c) that such
misappropriation or conversion or denial is to the prejudice of another; and (d) that there is a
demand made by the offended party on the offender.

RULING:
1. The Supreme Court ruled that indeed the petitioner Lito Corpuz was
guilty of the crime of estafa. In its decision about the punishment the
Supreme Court stated that there seems to be perceived injustice brought
by range of penalties, but the high court said that they modify the
penalties for that would constitute judicial legislation and that such duty
does not belong to the court but to the legislature. Other Justices has
their own opinion as to the punishment, some concurs with the ponente,
others invoked the Art. 5 of the RPC. that in case of excessive penalties
the court shall render the proper decision and shall report to the chief
executive the reasons that such said act should be made subject of
legislation and without suspending the sentence. Justice Carpio in his
dissenting opinion said that the first paragraph of Article 315 should be
held unconstitutional as it is against Article 19(1) of the Constitution and
that according to the Universal declaration of human rights “torture,
cruel, degrading and inhuman punishment should be ban”, the
Philippines was one of the approving State/Community during the UDHR
and although is a non-binding instrument, such UDHR forms part of the
Philippine law for it is a generally accepted principle of the international
law.