Panahon v. People
REITERATIONFacts
The Antecedents: Evelyn Panahon was engaged in selling ready-to-wear (RTW) clothes from Hongkong. She enticed Susan Jocson to invest ₱21,163.25 in her business, representing that she would use the money to buy RTW clothes abroad for sale in the Philippines. However, Panahon never left the country and did not return the money or the clothes. Procedural History: Four separate Informations for Estafa were filed against Panahon. The Regional Trial Court (RTC) acquitted her in three cases but convicted her in Criminal Case No. 91-4835 for Estafa under Article 315, paragraph 2(a) of the Revised Penal Code. The RTC sentenced her to imprisonment and ordered her to pay Susan Jocson the amount of ₱21,163.25 plus interest. The Court of Appeals (CA) affirmed the conviction. Panahon's motion for reconsideration was denied. The Petition: Panahon filed a petition for review on certiorari, arguing that the lone testimony of complainant Susan Jocson was insufficient to sustain her conviction.
Issue(s)
Whether the lone testimony of the private complainant is sufficient to sustain a conviction for Estafa. Whether the penalty imposed by the trial court, as affirmed by the Court of Appeals, is correct.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the testimony of a single witness, if credible and positive, is sufficient for conviction. The Court also affirmed the penalty imposed by the lower courts.
Ratio Decidendi
On the sufficiency of the lone testimony of the private complainant: The Court reiterated the settled rule that the testimony of a single witness, if credible, positive, and satisfies the court beyond reasonable doubt, is sufficient to convict. The absence of corroborating testimony does not affect credibility, as witnesses are weighed, not numbered. In this case, the RTC and CA found Susan Jocson's testimony credible and trustworthy. The circumstances, including their long-standing friendship, townmate and neighbor relationship, and the fact that Panahon was a "comadre" of Susan's sister, supported the trust reposed in Panahon. No evil motive was ascribed to Susan Jocson, making her testimony credible. The Court also emphasized that considerable weight is given to the factual findings of trial courts, which are in the best position to observe witness demeanor, and these findings were affirmed by the appellate court. Furthermore, in petitions for review on certiorari, the Supreme Court is not a trier of facts, limiting its review to questions of law. On the correctness of the penalty imposed: The Court disagreed with the Solicitor General's submission regarding the penalty. Applying the Indeterminate Sentence Law to the amount involved (₱21,163.25) and the provisions of Article 315 of the Revised Penal Code, the Court found that the penalty of "prision correccional" in its maximum period to "prision mayor" in its minimum period was applicable. The Indeterminate Sentence Law dictates that the correct penalty is "arresto mayor" in its maximum period, as minimum, to "prision mayor" in its minimum period, as maximum. Therefore, the trial court's imposition of an indeterminate penalty of imprisonment from six (6) months, as minimum, to six (6) years and one (1) day, as maximum, was deemed correct.
Main Doctrine
The testimony of a single witness, if credible, positive, and satisfies the court beyond reasonable doubt, is sufficient to convict. Witnesses are weighed, not numbered. Considerable weight is given to the factual findings of trial courts, especially when affirmed by the appellate court.