People v. Dimat
REITERATIONFacts
The Antecedents: The government charged Mel Dimat with violation of the Anti-Fencing Law. Samson Delgado testified that his wife, Sonia, bought a 1997 Nissan Safari from Dimat for ₱850,000.00. Police officers spotted the vehicle, discovered its engine and chassis numbers did not match the registration, and found it was on the list of stolen vehicles. The vehicle was stolen from its registered owner, Jose Mantequilla, in May 1998. Procedural History: The Regional Trial Court (RTC) found Dimat guilty of violating the Anti-Fencing Law and sentenced him to imprisonment and damages. The Court of Appeals (CA) affirmed the RTC decision but modified the penalty. Dimat appealed to the Supreme Court. The Petition: The sole issue before the Supreme Court was whether the CA correctly ruled that Dimat knowingly sold the stolen Nissan Safari for gain.
Issue(s)
Whether the Court of Appeals correctly ruled that accused Dimat knowingly sold to Sonia Delgado for gain the Nissan Safari that was earlier carnapped from Mantequilla.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of Mel Dimat for violation of the Anti-Fencing Law.
Ratio Decidendi
On the issue of whether Dimat knowingly sold the stolen Nissan Safari for gain: The Court held that the elements of fencing are: (1) a robbery or theft has been committed; (2) the accused, who took no part in the robbery or theft, buys, receives, possesses, keeps, acquires, conceals, sells or disposes, or buys and sells, or in any manner deals in any article or object taken during that robbery or theft; (3) the accused knows or should have known that the thing derived from that crime; and (4) he intends by the deal he makes to gain for himself or for another. In this case, Mantequilla's Nissan Safari was carnapped, and Dimat sold a similar vehicle two years later. Dimat's defense that he bought the vehicle in good faith from Manuel Tolentino was found to be flawed because the vehicle stopped by the police had the engine and chassis numbers of the stolen vehicle, indicating the deeds of sale did not reflect the correct numbers. Furthermore, Dimat's claim of lack of criminal intent was unavailing because Presidential Decree 1612 is a special law and its violation is considered malum prohibitum, requiring no proof of criminal intent. However, the prosecution must still prove that Dimat knew or should have known that the vehicle was derived from theft or robbery and that he intended to gain from the transaction. Dimat's testimony that Tolentino gave him the vehicle as collateral for a loan and promised new documents, which were not delivered, indicated that Dimat knew the vehicle was not properly documented and likely came from an illicit source. His subsequent sale of the vehicle to Sonia Delgado, despite these circumstances, confirmed his intent to gain from the illicit transaction.
Main Doctrine
To prove the crime of fencing under Presidential Decree 1612, the prosecution must establish that the accused knew or should have known that the object bought or sold was the fruit of theft or robbery, and that the accused intended to gain from the transaction. The law is considered malum prohibitum, thus, criminal intent is not a necessary element, but knowledge of the illicit origin of the property is.