Hernandez v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Danilo Hernandez was introduced to Remedios de Leon as a jewelry buyer and seller. Their transactions involved cash payments and postdated checks. Several checks issued by petitioner bounced due to insufficient funds or closed accounts. Petitioner was charged in nine separate informations with estafa and violation of B.P. Blg. 22 for various jewelry transactions involving checks issued to de Leon. Procedural History: The Regional Trial Court (RTC), Branch 17, Cavite City, convicted petitioner in all nine cases. On appeal, the Court of Appeals (CA) affirmed the conviction for most cases but acquitted petitioner in Criminal Case No. 21-87. The CA's decision found the RTC's decision to be in accordance with law and evidence. The Petition: Petitioner sought review of the CA's decision, raising issues regarding the propriety of a single judgment for multiple offenses, the CA's alleged failure to make complete findings of fact, its adoption of the Solicitor General's statement of facts, the denial of his motion for reconsideration, the sufficiency of evidence, the basis for civil indemnity, the authenticity of his signatures on the checks, and the effect of the offended party depositing the checks.
Issue(s)
Whether the trial court erred in rendering a single judgment for nine distinct offenses covered by separate informations. Whether the Court of Appeals erred in not making complete findings of fact for all assigned errors. Whether the Court of Appeals violated the constitutional mandate by adopting the Solicitor General's statement of facts and by denying the motion for reconsideration without stating legal bases. Whether the trial court's decision is supported by evidence, particularly regarding the existence, ownership, and worth of the jewelry. Whether the authenticity of the signatures on the checks is proven and whether the offended party's deposit of the checks with a bank affects the petitioner's liability.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed. Petitioner Danilo Hernandez is found guilty beyond reasonable doubt for the offenses of estafa and violation of B.P. Blg. 22, as affirmed by the Court of Appeals.
Ratio Decidendi
On the propriety of a single judgment for multiple offenses: The Court held that rendering a judgment for each of the nine separate informations in the same decision is not an error. This is permissible, especially when the trials are conducted jointly without objection. The Court distinguished this from a situation where a single judgment is rendered for two offenses in separate cases without consolidation. The rules allow consolidation of trials for offenses founded on the same facts or forming a series of offenses of similar character, at the court's discretion. Petitioner's failure to object to the joint trial further waived any right to complain about it later. The Court emphasized that the trial court rendered a judgment for each information, not a single judgment encompassing all nine offenses as a unified crime. On the Court of Appeals' findings of fact and adoption of the Solicitor General's statement: The Court found no error in the Court of Appeals adopting the Solicitor General's statement of facts. The constitutional mandate requires decisions to state the facts and the law on which they are based, but it does not prohibit the adoption of facts presented in briefs or memoranda, especially when supported by evidence. The Court noted that the appellate court also made its own findings of fact in the course of discussing the assigned errors. The denial of the motion for reconsideration was based on the finding that there were no cogent reasons to modify or reverse the decision, which is a sufficient legal basis. On the sufficiency of evidence regarding the existence, ownership, and worth of the jewelry: The Court rejected the petitioner's claim that the trial court's decision was not supported by evidence. The testimony of the offended party, Remedios de Leon, was deemed sufficient to sustain the conviction, even if she were the sole witness. The Court clarified that testimonies made in court under oath, with opportunity for cross-examination, are not considered inadmissible "self-serving statements." The existence of the jewelry was established by de Leon's testimony, and ownership is not a necessary element of estafa; prejudice to another is sufficient. The civil indemnity was based on the agreed price of the jewelry, reflected in the checks. On the sufficiency of evidence regarding the authenticity of the signatures: The Court held that if petitioner claimed his signatures on the checks were forged, the burden of proof was on him. His report of lost checks to the police was given little weight, especially since he did not file a criminal case against de Leon if the checks were indeed stolen. On the effect of check deposit on petitioner's liability: The cited case of Banco de Oro v. Equitable Banking Corporation was deemed inapplicable as it dealt with the negligence of a collecting bank with a forged endorsement, a different issue from the present case. The deposit of checks by the offended party does not absolve the petitioner of his liability for issuing bouncing checks.
Main Doctrine
The joint trial of multiple criminal informations founded on similar facts or forming a series of offenses of a similar character is permissible, even without explicit consolidation, provided no objection is raised by the accused. Furthermore, the testimony of a single credible witness, even if the offended party, is sufficient to sustain a conviction, and the weight of evidence is determined by the credibility of witnesses, not their number. Ownership of the property subject of estafa is not a necessary element; the prejudice suffered by another is sufficient.