Tan v. People
REITERATIONFacts
The Antecedents: Plaintiff-appellant Inocencio Tan and Antonio Conejero were accused of estafa by means of false pretenses. The information alleged that they falsely pretended to possess influence on President Carlos P. Garcia and Executive Secretary Pajo to facilitate the release of a P250,000.00 loan from the Philippine National Bank for Fernando E. Ricafort. They induced Ricafort to give them P2,000.00, which they misappropriated. Procedural History: The trial court acquitted Antonio Conejero but convicted Inocencio Tan for consummated estafa. The Court of Appeals modified the judgment, convicting Tan only for attempted estafa. The Supreme Court denied Tan's petition for review. The Petition: Tan filed a civil case to annul the judgment of conviction, alleging that the information was fatally defective and that criminal jurisdiction did not attach. The civil case was dismissed by the Court of First Instance. Tan appealed this dismissal to the Supreme Court.
Issue(s)
Whether a branch of the Court of First Instance can annul a judgment rendered by another branch of the same court. Whether the information filed against the plaintiff-appellant sufficiently alleged the elements of estafa by means of false pretenses.
Ruling
The Supreme Court affirmed the judgment of the lower court dismissing the complaint for annulment of judgment. The Court held that a branch of the Court of First Instance cannot annul a judgment rendered by another branch of the same court, and that the information was sufficient to charge estafa by false pretenses.
Ratio Decidendi
On the issue of jurisdiction to annul a judgment: The Court reiterated the rule that the jurisdiction to annul a judgment of a branch of the Court of First Instance belongs solely to the very same branch which rendered the judgment. Allowing another branch to annul a judgment would constitute exceeding its jurisdiction or acting with grave abuse of discretion amounting to lack of jurisdiction. Therefore, the appeal should be dismissed on this ground alone. On the sufficiency of the information: The Court examined the information and found that it sufficiently alleged the elements of estafa by means of false pretenses under Article 315(2)(a) of the Revised Penal Code. The information averred that the accused falsely pretended to possess influence on the President and Executive Secretary, which they knew to be false, and made these representations to induce the injured party to part with P2,000.00. The averment that the accused "succeeded in inducing" the injured party to deliver the money sufficiently alleged the element of reliance. Finally, the phrase "to the damage and prejudice of said Fernando E. Ricafort in the aforesaid sum of P2,000.00" constituted the averment of damages. Thus, there was no basis for the claim that the plaintiff-appellant's constitutional right to be informed of the nature and cause of his accusation was violated.
Main Doctrine
A court of first instance branch cannot annul a judgment rendered by another branch of the same court, as such power belongs solely to the branch that rendered the judgment. Furthermore, an information for estafa by false pretenses is sufficient if it alleges the false pretenses used, the victim's reliance thereon, and the resulting damage.