Facts: Ma. Lourdes Deutsch, together with Nercy M. Demeterio, Excel Mangubat, and spouses Numeriano Rabadon and Leonila Burlaos, were charged with Estafa for selling a portion of beach property to Ma. Milagros G. Wilson for P250,000.00 while misrepresenting that it was free from liens despite being under the Comprehensive Agrarian Reform Program (CARP) coverage. The accused received a P164,000.00 downpayment from Wilson, who later demanded the downpayment’s return upon discovering the deception.
Demeterio and Mangubat pleaded not guilty, as did Deutsch and the Rabadons. However, only the Rabadons were discharged to become state witnesses. The trial court convicted Deutsch, Demeterio, and Mangubat of Estafa, sentencing them to prison and ordering them to pay damages and reimbursement to Wilson.
Upon appeal, the Court of Appeals acquitted Deutsch, citing insufficient evidence, but modified the judgment for Demeterio and Mangubat, reducing the damages and adjusting the penalty they had to serve, while maintaining their guilt.
Wilson filed a Motion for Reconsideration which was denied, triggering her petition for review on certiorari under Rule 45 before the Supreme Court. Demeterio and Mangubat, whose subsequential Motion for Reconsideration had been denied too, likewise filed a petition for review on certiorari challenging their conviction.
Issues:
1. Whether the petition for review on certiorari was the appropriate remedy invoked by Wilson.
2. Whether the Court of Appeals acted with grave abuse of discretion in acquitting Ma. Lourdes Deutsch.
3. Whether the petition filed by Demeterio and Mangubat in G.R.No. 134553 was timely.
4. Whether Demeterio and Mangubat were properly convicted of Estafa and held liable for damages.
Court’s Decision:
The Supreme Court denied both petitions. In G.R. No. 132396, it held that Wilson had invoked an inappropriate remedy, as grave abuse of discretion is not a ground under Rule 45. Furthermore, it found that the Court of Appeals did not act with grave abuse of discretion when it acquitted Deutsch, as the decision was based on the evidence presented and not tainted by arbitrariness.
In G.R. No. 134553, the Court noted the tardiness of the petition filed by Demeterio and Mangubat, as it was filed four months beyond the 15-day period for filing a motion for reconsideration or an appeal under Rule 45. Due to the lapse of time, the Court of Appeals’ decision had become final and executory against them. The Court also upheld the findings and judgment of the lower courts regarding their conviction and liabilities.
Doctrine: The doctrine of finality of acquittal was upheld. An acquittal cannot be appealed without placing the accused in double jeopardy unless it is established that the court acted with grave abuse of discretion amounting to lack or excess of jurisdiction. The Supreme Court also affirmed the distinctiveness of Rule 45 and Rule 65 remedies.
Class Notes:
1. Swindling (Estafa) under Article 315, Revised Penal Code.
2. The doctrine of double jeopardy: legal jeopardy attaches only upon a valid indictment, before a competent court, after arraignment, a valid plea is entered, and the case is dismissed or otherwise terminated without the express consent of the accused.
3. Remedies distinction: Rule 45 of the Rules of Court addresses errors of judgment (petition for review on certiorari), whereas Rule 65 involves errors of jurisdiction or grave abuse of discretion (certiorari).
4. Finality of Decisions: decisions not appealed within the reglementary period become final and executory. (Rule 45, Section 2; Rule 65, Section 4)
Historical Background: This case illustrates the procedural intricacies of Philippine jurisprudence, highlighting the balance between finality of decisions and the pursuit of justice, especially in the appeal processes in criminal law. It also showcases the importance of timely filing petitions to avoid the consequences of a decision becoming final and executory. The case reflects the evolving interpretations of legal doctrines relating to double jeopardy and the appellate system in the Philippines.
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