People v. Angco
REITERATIONFacts
The Antecedents: Vicente Angco, a Traveling Sales Agent for the Philippine Charity Sweepstakes Office (PCSO) with headquarters in Tuguegarao, Cagayan, was charged with malversation of public funds. He was entrusted with selling sweepstakes tickets and obligated to remit the proceeds to the PCSO Treasurer in Manila. Angco received 171 booklets of tickets for the February 25, 1951 draw, valued at P5,377.95. He accounted for and turned over only P1,417, leaving a balance of P3,960.95 unaccounted for. Procedural History: The Court of First Instance of Manila found Angco guilty of malversation and sentenced him to an indeterminate penalty, to indemnify the offended party, and to pay costs. Angco appealed, assigning errors related to the court's jurisdiction and the denial of his right to counsel and to present evidence. The Petition: The appellant contended that the trial court lacked jurisdiction because the malversation allegedly occurred in Cagayan, not Manila. He also argued that the court erred in not providing him with a counsel de officio and in not allowing him to present evidence.
Issue(s)
Whether the Court of First Instance of Manila has jurisdiction over the crime of malversation committed by a traveling sales agent whose headquarters were in Cagayan but was obligated to remit proceeds to Manila. Whether the trial court erred in not providing the accused with a counsel de officio and in not allowing him to present evidence.
Ruling
The Supreme Court affirmed the judgment of the trial court, with modification as to the penalty. The Court ruled that the Court of First Instance of Manila has jurisdiction over the case and that the accused waived his right to present evidence due to his repeated failure to appear with counsel.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the Court of First Instance of Manila has jurisdiction. The information alleged that Angco was a "Travelling Sales Agent of the Philippine Charity Sweepstakes Office, in said City [Manila]," and was "charged with selling sweepstakes tickets entrusted to him for sale in his district, with the obligation of turning over the proceeds of the sale of said tickets to the treasurer of the Philippine Charity Sweepstakes Office in Manila." The Court found these allegations sufficient to confer jurisdiction upon the Court of First Instance of Manila, to the exclusion of the concurrent jurisdiction of the Court of First Instance of Cagayan. The trial court's findings that Angco was bonded, authorized to sell tickets, and obligated to remit proceeds to Manila supported the charge. On the issue of right to counsel and presentation of evidence: The Court found no error in the trial court's proceedings. The record showed that Angco was represented by counsel of his choice during arraignment and trial. His counsel filed motions to dismiss and for postponement. The trial court granted several postponements, warning that failure to present evidence would be deemed a waiver. Angco's repeated failure to appear with counsel, despite these warnings and postponements, was deemed a deliberate attempt to delay proceedings and constituted a waiver of his right to present evidence. Therefore, the trial court was justified in proceeding with the judgment based on the prosecution's evidence.
Main Doctrine
The Court of First Instance of Manila has jurisdiction over a malversation case where the accused, a traveling sales agent with headquarters in Cagayan, was obligated to turn over proceeds to the Treasurer in Manila, and the misappropriation occurred in relation to these funds. Furthermore, a defendant's repeated failure to appear with counsel, despite numerous postponements and warnings, constitutes a waiver of the right to present evidence and justifies the court in proceeding with the judgment based on the prosecution's evidence.