Mercado v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The petitioner, Engr. Isagani Mercado, was accused of estafa under Article 315, paragraph 2(a) of the Revised Penal Code. Five prosecution witnesses testified that they, along with six others, each gave P5,000 to the petitioner on November 5, 1984, in Lumban, Laguna. This money was given based on Mercado's representation that he would help them find overseas employment. The total amount collected was P55,000.00, for which Mercado issued a single receipt. The promised overseas jobs never materialized. 2. Procedural History: The Regional Trial Court (RTC) found Engr. Isagani Mercado guilty beyond reasonable doubt of estafa. The RTC rejected Mercado's alibi, which claimed he was confined at the Manila Sanitarium from November 5-9, 1984, noting that the time of admission was not specified and it would have been possible for him to travel from Manila to Lumban. The court also considered Mercado's failure to question the genuineness of his signature on the receipt as an admission. The Court of Appeals affirmed the RTC's decision, with a modification to the minimum indeterminate sentence, finding that the alibi was not sufficiently supported by hospital records and that the prosecution witnesses' testimonies were consistent and credible despite minor inconsistencies. 3. The Petition: Engr. Isagani Mercado filed a petition for review on certiorari with the Supreme Court, seeking to reverse the decision of the Court of Appeals. His assignments of error included the appellate court's alleged grave abuse of discretion in relying on a cited case (People vs. Abaya) that he claimed was inapplicable, its oversight of a certification from Dr. Pacita Timonera regarding his confinement, and conflicting findings of fact between the RTC and the Court of Appeals. He argued that the appellate court overlooked undisputed facts that would lead to a different conclusion and that the certification of his confinement was not disputed by the prosecution.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in relying on the cited case of People of the Philippines v. Abaya. Whether the Court of Appeals manifestly overlooked the certification from Dr. Pacita Timonera regarding the petitioner's confinement. Whether the findings of fact of the Regional Trial Court and the Court of Appeals are conflicting.
Ruling
The Supreme Court RESOLVED to reconsider its resolution of February 23, 1994, giving due course to the petition for review on certiorari, and to DENY the petition for review, affirming the decision of the Court of Appeals.
Ratio Decidendi
On the first assignment of error (reliance on People v. Abaya): The Supreme Court found no major discrepancies in the testimonies of the prosecution witnesses. The Court emphasized that the crucial aspect was the positive identification of the petitioner by all witnesses as the person to whom they paid money, which was made easier by their familiarity with him as a townmate and relative. Inconsistencies were deemed natural variations in perception. The Court reiterated the principle that minor lapses in testimonies do not necessarily impair credibility as long as the testimonies are consistent and believable as a whole, aligning with the cited case. On the second assignment of error (overlooking the certification): The Court held that the petitioner's alibi, supported only by his own self-serving testimony and a certification whose issuance date was questioned, was insufficient to overturn the overwhelming evidence against him. The RTC's rejection of the alibi was based on the lack of proof that it was impossible for him to be in Lumban, Laguna at the time of the commission of the crime, considering the travel time from Manila and the absence of evidence of serious illness. The CA also found the hospital records lacking in specifying the time of admission. On the third assignment of error (conflicting findings of fact): The Court clarified that the perceived conflict was more apparent than real. While the RTC considered the petitioner's failure to question the signature on the receipt as an admission, the petitioner argued that the CA found he did question its authenticity. The appellate court's explanation was that the receipt was submitted for NBI examination at the petitioner's suggestion, but the proceedings were suspended when petitioner's counsel withdrew. The new counsel proceeded without waiting for the NBI results, and the petitioner failed to provide the necessary genuine signatures for comparison. The appellate court's focus was on the petitioner questioning what appeared on top of the signature, not the signature itself. The Court reiterated that factual findings of the appellate court are generally binding and will not be disturbed unless shown to be contrary to the evidence on record, which was not demonstrated by the petitioner.
Main Doctrine
The Court of Appeals' factual findings, when supported by evidence on record, are generally binding and will not be disturbed on review, especially when the Supreme Court finds no reversible error warranting reversal.