People vs.
Ilarde
G.R. No. L-58595
Oct 10, 1983
Facts:
The case involves the People of the Philippines as the petitioner and Hon. Ricardo M. Ilarde, in his
capacity as Presiding Judge of the Court of First Instance (now Regional Trial Court) of Iloilo, Branch V,
along with Cecile Santibanez and Avelino T. Javellana as respondents. The events leading to this case
began on November 3, 1980, in Iloilo City, where Efraim Santibanez, the offended party, caught his wife,
Cecile Santibanez, in the act of adultery with Avelino T. Javellana. Efraim, upon learning of his wife's
infidelity from their son, devised a plan to catch her red-handed. He removed a glass from the jalousie
window of their bedroom to observe the illicit act. Following the incident, Efraim filed a sworn complaint
with the Integrated National Police on November 4, 1980, which was forwarded to the City Fiscal for
preliminary investigation.
On March 4, 1981, City Fiscal Ricardo P. Galvez filed an information for adultery against Cecile and
Avelino, citing the sworn complaint and an affidavit-complaint from Efraim. However, before the
preliminary investigation concluded, Efraim was diagnosed with cancer and left for the United States for
treatment, where he passed away on February 16, 1981. Despite his death, the City Fiscal proceeded to
file the information on March 3, 1981. The private respondents filed a motion to quash the information,
arguing that the court lacked jurisdiction since the offended party had not filed the required complaint
as mandated by Article 344 of the Revised Penal Code and Section 4, Rule 110 of the Rules of Court. The
respondent judge granted the motion, leading to the present petition for review on certiorari.
Issue:
1. Did the court acquire jurisdiction over the offense charged despite the death of the offended
party, Efraim Santibanez, before the filing of the information?
2. Was there compliance with the requirement of Article 344 of the Revised Penal Code regarding
the filing of a complaint by the offended spouse?
Ruling:
The Supreme Court ruled in favor of the petitioner, granting the petition for review on certiorari. The
orders of the Court of First Instance of Iloilo, Branch V, which quashed the information in Criminal Case
No. 13086, were set aside. The respondent judge was directed to proceed with the trial of the case on its
merits.
Quimvel y Braga vs. People
G.R. No. 214497
Apr 18, 2017
Facts:
The case involves Eduardo Quimvel y Braga, the petitioner, who was accused of committing acts of
lasciviousness against a minor, referred to as AAA, who was only seven years old at the time of the
incident. The events took place on July 18, 2007, at around 8 o'clock in the evening in Palapas, Ligao City,
Philippines. At that time, AAA was living with her father, who was a Barangay Tanod, and her siblings,
while their mother was working as a household helper in Batangas. Quimvel was the caretaker of AAA's
grandfather's ducks and lived nearby. On the night of the incident, AAA's father left the house to buy
kerosene, leaving the children alone. Quimvel visited the house to bring a vegetable viand from AAA's
grandfather. After AAA requested him to stay with them due to fear, he agreed. Later, while the children
were asleep, AAA awoke to find Quimvel's leg on her body and his hand inside her panty, caressing her
vagina. She managed to remove his hand just as her father returned home. Following the incident, AAA
disclosed the events to her mother, who reported the matter to the authorities. Quimvel denied the
allegations, claiming he was not present at the house during the incident. The Regional Trial Court found
him guilty of acts of lasciviousness in relation to Section 5(b) of Republic Act No. 7610, sentencing him to
imprisonment and ordering him to pay damages to the victim. The Court of Appeals affirmed the RTC's
decision with modifications regarding the damages.
Issue:
1. Did the Court of Appeals err in affirming the trial court's decision, claiming that the prosecution
failed to prove Quimvel's guilt beyond a reasonable doubt?
2. Assuming Quimvel is guilty, should he be convicted only under Article 336 of the Revised Penal
Code and not in relation to Section 5(b) of RA 7610?
Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, finding Quimvel guilty beyond
reasonable doubt of acts of lasciviousness as penalized under Section 5(b) of RA 7610. The Court ruled
that the elements of the crime were sufficiently alleged and proven, including the circumstances of
coercion and influence over the minor victim.
Malto vs. People
G.R. No. 164733
Sep 21, 2007
Facts:
The case involves Michael John Z. Malto, a professor at Assumption College, who was accused of
violating the Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act (RA
7610). The events took place in Pasay City, Metro Manila, from November 1997 to 1998. The
complainant, referred to as AAA, was a 17-year-old student in Malto's Philosophy II class. The
prosecution's case established that Malto had engaged in inappropriate conduct with AAA, including
sexual advances and acts of lasciviousness. The initial information charged him with violating Section
5(b), Article III of RA 7610, but this was later amended to Section 5(a). During the trial, AAA testified
about several incidents where Malto exerted his influence and moral ascendancy over her, leading to
sexual intercourse and lascivious conduct. Malto denied the allegations, claiming that the incidents did
not occur and that he had a consensual relationship with AAA after she turned 19. The Regional Trial
Court found Malto guilty and sentenced him to reclusion temporal. Malto appealed to the Court of
Appeals, which affirmed the conviction but modified the penalty and civil indemnity awarded to AAA.
The case was then brought before the Supreme Court for review.
Issue:
1. Did the Court of Appeals err in affirming Malto's conviction despite finding that his acts were not
covered by paragraph (a) but by paragraph (b) of Section 5, Article III of RA 7610?
2. Was the designation of the offense in the information sufficient to inform Malto of the charges
against him?
3. Can the "sweetheart theory" be invoked in cases involving minors under RA 7610?
4. Is Malto entitled to the benefits of the Indeterminate Sentence Law?
5. Should the award of damages be modified?
Ruling:
1. The Court of Appeals did not err in affirming Malto's conviction, as the facts supported a charge
under Section 5(b).
2. The designation of the offense in the information was sufficient, as the facts alleged clearly
constituted the crime charged.
3. The "sweetheart theory" cannot be invoked in cases involving minors under RA 7610, as consent
is immaterial.
4. Malto is entitled to the benefits of the Indeterminate Sentence Law.
5. The award of damages should be modified, with civil indemnity set at P50,000 and moral
damages also at P50,000.
People vs. Valdez
G.R. No. 175602
Facts:
In the case of People of the Philippines vs. PO2 Eduardo Valdez and Edwin Valdez, the accused were
charged with three counts of murder for the killings of Ferdinand Sayson, Moises Sayson, Jr., and Joselito
Sayson, which occurred on March 1, 2000, in Quezon City, Philippines. The Regional Trial Court (RTC) of
Quezon City, Branch 86, convicted both accused on January 20, 2005, sentencing them to reclusion
perpetua for each count and ordering them to pay damages to the victims' heirs. The Court of Appeals
(CA) upheld the RTC's decision on July 18, 2006, but modified the damages awarded. The case arose
from an incident at a canteen where the victims were celebrating a birthday. The accused, armed with
firearms, confronted the victims, leading to a violent altercation where all three victims were shot. The
prosecution presented eyewitness accounts, while the defense claimed self-defense and argued that the
victims were the aggressors. Edwin Valdez later withdrew his appeal, leaving PO2 Eduardo Valdez's
appeal for resolution.
Issue:
1. Did the Court of Appeals err in affirming the RTC's conviction of PO2 Eduardo Valdez for murder
despite the alleged inconsistencies in witness testimonies?
2. Was there sufficient evidence to establish the existence of conspiracy between the accused?
3. Did the State adequately prove the qualifying circumstance of treachery in the commission of
the crime?
Ruling:
The Supreme Court modified the CA's decision, finding PO2 Eduardo Valdez guilty of three counts of
homicide instead of murder due to the failure of the informations to sufficiently allege the presence of
treachery. The Court affirmed the conviction but reduced the penalty to an indeterminate sentence of 10
years of prision mayor as minimum to 17 years of reclusion temporal as maximum for each count of
homicide, along with the corresponding damages to the victims' heirs.
Miguel vs. Sandiganbayan
G.R. No. 172035
Facts:
The case involves Fernando Q. Miguel (petitioner) and the Honorable Sandiganbayan (respondent). The
events leading to this case began on May 29, 1996, when then Vice Mayor Mercelita M. Lucido and other
local officials of Koronadal City, South Cotabato, filed a letter-complaint with the Office of the
Ombudsman-Mindanao against the petitioner and others. They were charged with violations of Republic
Act (R.A.) No. 3019 concerning consultancy services for the architectural, engineering design, and
construction supervision of the proposed Koronadal City public market. Following an order from the
Ombudsman on June 27, 1996, the petitioner submitted his counter-affidavit on October 23, 1996, after
requesting an extension. On July 29, 1999, the Ombudsman found probable cause against the petitioner
for violating R.A. No. 3019 and for Falsification of Public Document under Article 171, paragraph 4 of the
Revised Penal Code. Consequently, on March 1, 2000, the Ombudsman filed the corresponding
informations with the Sandiganbayan.
The information alleged that on January 10, 1995, the petitioner, as the former Municipal Mayor of
Koronadal, acted with evident bad faith and manifest partiality by inviting only certain private individuals
to participate in the prequalification of consultants for the project, without publishing the invitation in a
newspaper of general circulation. This exclusion of other consultants was deemed to have given
unwarranted benefits to the private individuals involved.
Subsequent motions for reinvestigation were filed by the petitioner and his co-accused, which the
Sandiganbayan granted. However, despite being given multiple extensions to submit his counter-
affidavit, the petitioner failed to do so, leading to a declaration of waiver of his right to present
countervailing evidence. On April 28, 2005, the Office of the Special Prosecutor (OSP) filed a Motion to
Suspend the petitioner pendente lite. The Sandiganbayan issued a resolution on January 25, 2006,
suspending the petitioner from his position as City Mayor for 90 days. The petitioner filed a motion for
reconsideration, which was denied, prompting him to file a petition for certiorari under Rule 65 to
challenge the suspension order.
Issue:
1. Is the information charging the petitioner with violation of Section 3(e) of R.A. No. 3019 valid?
2. If the information is valid, does the absence of an actual pre-suspension hearing invalidate the
suspension order against the petitioner?
Ruling:
The Supreme Court dismissed the petition for lack of merit, affirming the validity of the information
against the petitioner and upholding the suspension order issued by the Sandiganbayan.
People vs. Solar y Dumbrique
G.R. No. 225595
Aug 6, 2019
Facts:
The case involves Rolando Solar y Dumbrique (the accused-appellant) and the People of the Philippines
(the plaintiff-appellee). The events transpired on March 9, 2008, in Las Piñas City, Philippines. An
Information was filed against Rolando and his co-accused, Mark Kenneth Solar, for the murder of Joseph
Capinig y Mato. The Information alleged that both accused conspired to kill Joseph by attacking him with
a baseball bat, inflicting fatal injuries. During the arraignment, Rolando pleaded not guilty, while Mark
Kenneth remained at large. The prosecution presented Ma. Theresa Capinig, the victim's wife, as the sole
eyewitness, along with Dr. Voltaire Nulud, who conducted the medical examination on Joseph. Ma.
Theresa testified that she witnessed Rolando and Mark Kenneth assaulting her husband. The defense,
however, claimed that Rolando was at a wake during the incident and that Joseph had attacked him first
with a knife. After trial, the Regional Trial Court (RTC) convicted Rolando of murder on September 3,
2012, sentencing him to reclusion perpetua and ordering him to pay damages to the victim's heirs.
Rolando appealed to the Court of Appeals (CA), which affirmed the RTC's decision but downgraded the
conviction from murder to homicide, citing insufficient details in the Information regarding the qualifying
circumstance of treachery. Rolando then filed an appeal to the Supreme Court.
Issue:
1. Did the CA err in convicting Rolando despite the prosecution's failure to prove his guilt beyond
reasonable doubt?
2. Did the CA err in convicting Rolando despite the prosecution's failure to prove that conspiracy
existed between him and Mark Kenneth?
Ruling:
The Supreme Court ruled that the appeal was unmeritorious. It affirmed the conviction of Rolando for
the crime of murder, reversing the CA's downgrade to homicide. The Court found that the prosecution
had proven Rolando's guilt beyond reasonable doubt and that conspiracy existed between him and Mark
Kenneth.
People vs. Vidana
G.R. No. 199210
Facts:
The case involves the People of the Philippines as the plaintiff-appellee against Ricardo M. VidaAa, the
accused-appellant. The events leading to this case transpired on September 16, 2003, in Sta. Maria,
Licab, Nueva Ecija. The accused, Ricardo M. VidaAa, was charged with one count of rape under Republic
Act No. 7610, known as the Special Protection of Children Against Abuse, Exploitation and Discrimination
Act. The Information, dated February 6, 2004, alleged that VidaAa, with lewd designs and intent, had
carnal knowledge of his 15-year-old daughter, referred to as AAA, against her will and consent.
After a year of evading arrest, VidaAa was apprehended on September 1, 2004, and subsequently
arraigned on January 30, 2006, where he pleaded not guilty. The prosecution's narrative indicated that
on the night of the incident, VidaAa forcibly removed AAA's clothing and raped her while threatening her
life and that of her siblings if she disclosed the incident. The victim later confided in a family friend,
Zenny Joaquin, who accompanied her to the police to report the crime. A medico-legal examination
confirmed signs of sexual abuse.
In contrast, the defense claimed that AAA was not living with VidaAa at the time of the alleged incident
and that he was working in the fields during the hours when the crime supposedly occurred. The trial
court found VidaAa guilty beyond reasonable doubt, sentencing him to reclusion perpetua and ordering
him to pay moral damages to AAA. The Regional Trial Court's decision was appealed to the Court of
Appeals, which affirmed the lower court's ruling on March 18, 2011. VidaAa then sought further appeal,
contesting the conviction.
Issue:
1. Did the Court of Appeals err in affirming the conviction of Ricardo M. VidaAa for the crime of
rape under Republic Act No. 7610?
2. Was the testimony of AAA credible enough to support the conviction of her father?
3. Did the trial court properly characterize the offense and impose the correct penalties?
Ruling:
1. The Court of Appeals did not err in affirming the conviction of Ricardo M. VidaAa for the crime of
rape.
2. The testimony of AAA was deemed credible and sufficient to support the conviction.
3. The trial court's characterization of the offense was incorrect; the proper designation should
have been qualified rape, and the penalties were modified accordingly.
HECTOR TREÑAS VS. PEOPLE OF THE PHILIPPINES
G.R. No. 195002
January 25, 2012
Facts:
In December 1999, Margarita Alocilja was interested in purchasing a house-and-lot in Iloilo City, and the
property was mortgaged with Maybank. Maybank’s manager, Joselito Palma, recommended lawyer
Hector Treñas to Margarita’s niece Elizabeth for aid in transferring the title. Hector outlined that various
fee (attorney’s fees, capital gains tax, documentary stamps, and miscellaneous expenses) would amount
to ₱150,000. Elizabeth handed over this amount to Hector on December 22, 1999, for which he issued a
receipt. Hector provided Elizabeth with revenue receipts totaling ₱120,000 which Elizabeth later learned
from the BIR, were fake. Hector admitted to this and issued a ₱120,000 check to Elizabeth, which
bounced due to a closed account. Consequently, an estafa case was filed against Hector on October 29,
2001, the City Prosecutor filed an Information for estafa before the RTC of Makati City. Hector pleaded
“Not Guilty” on April 26, 2002, but due to health and other reasons, he could not attend pre-trial and
trial proceedings. On January 8, 2007, the RTC found Hector guilty and sentenced him to 10 years and 1
day of prision mayor to 17 years and 4 months of reclusion temporal, also ordering him to indemnify
Elizabeth. Hector filed a motion for reconsideration on August 24, 2007, which the RTC denied on July 2,
2008. He appealed on September 25, 2008, to the CA, which affirmed the RTC’s decision on July 9, 2010.
Hector’s motion for reconsideration was denied on January 4, 2011. Subsequently, Hector filed a petition
for review with the Supreme Court.
Issues:
1. Did the RTC of Makati City lack jurisdiction over the estafa case since the evidence suggested that the
essential elements of the crime did not occur in Makati City?
2. Was the demand for restitution properly made by Elizabeth, despite Margarita being the actual owner
of the funds?
Court’s Decision:
1. The Supreme Court held that jurisdiction in criminal cases is territorial and must be proved by
the prosecution. There was insufficient evidence that any element of estafa occurred in Makati
City. Failing to show where the crime occurred led to the conclusion that the RTC of Makati City
lacked jurisdiction.
2. The case did not meet any exceptions to the general rule precluding higher courts from
reassessing factual determinations. However, the prosecution’s evidence did not substantiate
the jurisdictional facts, leading to the dismissal of the estafa case without prejudice.
Union Bank of the Philippines vs. People
G.R. No. 192565
Facts:
The case involves Union Bank of the Philippines and Desi Tomas as petitioners against the People of the
Philippines as the respondent. The events leading to this case began on March 13, 2000, in Makati City,
where Desi Tomas was charged with perjury under Article 183 of the Revised Penal Code (RPC). The
charge stemmed from her execution of a Certificate against Forum Shopping, which was part of a
complaint for a sum of money with a prayer for a writ of replevin, docketed as Civil Case No. 342-00 in
the Metropolitan Trial Court (MeTC) of Pasay City. The Information alleged that Tomas made false
statements under oath, asserting that Union Bank had not commenced any other action involving the
same issues in another tribunal, despite knowing this to be untrue. This accusation arose from two
complaints filed by Union Bank against the spouses Eddie and Eliza Tamondong, the first of which was
filed on April 13, 1998, and the second on March 15, 2000. Tomas filed a Motion to Quash the
Information, arguing that the venue was improperly laid in Makati City instead of Pasay City, where the
Certificate was used. She also contended that the facts charged did not constitute an offense, as the
essential elements of perjury were not sufficiently alleged. The MeTC denied her motion, asserting
jurisdiction based on the notarization of the Certificate in Makati City. Tomas's subsequent motion for
reconsideration was also denied. The petitioners then filed a petition for certiorari before the Regional
Trial Court (RTC) of Makati City, which dismissed the petition, ruling that the MeTC did not commit grave
abuse of discretion. The RTC held that the proper venue for the perjury case was indeed in Makati City,
where the Certificate was notarized.
Issue:
1. What is the proper venue for the perjury charge against Desi Tomas under Article 183 of the
Revised Penal Code: Makati City, where the Certificate against Forum Shopping was notarized, or
Pasay City, where the Certificate was presented to the trial court?
Ruling:
The Supreme Court denied the petition, affirming that the MeTC-Makati City is the proper venue and
court to take cognizance of the perjury case against Desi Tomas.
