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    Corpuz v. People

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    Gia Dimayuga
    This case involved a defendant, Lito Corpuz, who was charged with estafa for failing to return jewelry items worth 98,000 pesos that were entrusted to him for sale. While the lower courts imposed prison sentences, the Supreme Court had to determine if it could modify outdated penalties in the penal code that were based on money values from 1930. The Court ultimately ruled that it did not have the authority to legislate and modify the penalties, as that power belongs solely with Congress. However, it affirmed the defendant's conviction and imposed an indeterminate prison sentence of 3 years, 2 months, and 11 days to 15 years based on the facts of the case and existing penal code provisions.

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    © All Rights Reserved
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    Corpuz v. People

    Uploaded by

    Gia Dimayuga
    126 views2 pages
    This case involved a defendant, Lito Corpuz, who was charged with estafa for failing to return jewelry items worth 98,000 pesos that were entrusted to him for sale. While the lower courts imposed prison sentences, the Supreme Court had to determine if it could modify outdated penalties in the penal code that were based on money values from 1930. The Court ultimately ruled that it did not have the authority to legislate and modify the penalties, as that power belongs solely with Congress. However, it affirmed the defendant's conviction and imposed an indeterminate prison sentence of 3 years, 2 months, and 11 days to 15 years based on the facts of the case and existing penal code provisions.

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    Criminal Law 1

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    This case involved a defendant, Lito Corpuz, who was charged with estafa for failing to return jewelry items worth 98,000 pesos that were entrusted to him for sale. While the lower courts imposed prison sentences, the Supreme Court had to determine if it could modify outdated penalties in the penal code that were based on money values from 1930. The Court ultimately ruled that it did not have the authority to legislate and modify the penalties, as that power belongs solely with Congress. However, it affirmed the defendant's conviction and imposed an indeterminate prison sentence of 3 years, 2 months, and 11 days to 15 years based on the facts of the case and existing penal code provisions.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    126 views2 pages

    Corpuz v. People

    Uploaded by

    Gia Dimayuga
    This case involved a defendant, Lito Corpuz, who was charged with estafa for failing to return jewelry items worth 98,000 pesos that were entrusted to him for sale. While the lower courts imposed prison sentences, the Supreme Court had to determine if it could modify outdated penalties in the penal code that were based on money values from 1930. The Court ultimately ruled that it did not have the authority to legislate and modify the penalties, as that power belongs solely with Congress. However, it affirmed the defendant's conviction and imposed an indeterminate prison sentence of 3 years, 2 months, and 11 days to 15 years based on the facts of the case and existing penal code provisions.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 2

    DIMAYUGA, GIANINA IRMA A.

    184034

    LITO CORPUZ vs. PEOPLE OF THE PHILIPPINES


    G.R. No. 180016, April 29, 2014
    Peralta, J:

    FACTS:
    Danilo Tangcoy turned over to Lito Corpuz the following items: an 18k diamond ring for
    men; a woman's bracelet; one (1) men's necklace and another men's bracelet, with an aggregate
    value of ₱98,000.00. They both agreed that petitioner shall remit the proceeds of the sale, and/or,
    if unsold, to return the same items, within a period of 60 days. The period expired without
    Corpuz remitting the proceeds of the sale or returning the pieces of jewelry. When private
    complainant was able to meet petitioner, the latter promised the former that he will pay the value
    of the said items entrusted to him, but to no avail. Corpuz was charged with the crime of Estafa.

    CA modified the ruling of the RTC. The RTC imposed the indeterminate penalty of four
    (4) years and two (2) months of prision correccional in its medium period, as minimum, to
    fourteen (14) years and eight (8) months of reclusion temporal in its minimum period, as
    maximum. However, the CA imposed the indeterminate penalty of four (4) years and two (2)
    months of prision correccional, as minimum, to eight (8) years of prision mayor, as maximum,
    plus one (1) year for each additional ₱10,000.00, or a total of seven (7) years.

    ISSUE/S:
    Whether or not the court could amend an outdated imposition of fines pegged according
    to the value of money in 1930 when the RPC was enacted?

    RULING: DENIED
    AFFIRMED with MODIFICATION that the penalty imposed is the indeterminate penalty
    of imprisonment ranging from THREE (3) YEARS, TWO (2) MONTHS and ELEVEN DAYS of
    prision correccional, as minimum, to FIFTEEN (15) YEARS of reclusion temporal as
    maximum. Pursuant to Article 5 of the Revised Penal Code, let a Copy of this Decision be
    furnished the President of the Republic of the Philippines, through the Department of Justice.
    Also, let a copy of this Decision be furnished the President of the Senate and the Speaker of the
    House of Representatives.

    RATIO DECIDENDI
    The Supreme Court's Third Division was deliberating on this case, the question of the
    continued validity of imposing on persons convicted of crimes involving property came up. The
    legislature apparently pegged these penalties to the value of the money and property in 1930
    when it enacted the Revised Penal Code. Since the members of the division reached no
    unanimity on this question and since the issues are of first impression, they decided to refer the
    case to the Court en banc for consideration and resolution.
    There seems to be a perceived injustice brought about by the range of penalties that the
    courts continue to impose on crimes against property committed today, based on the amount of
    damage measured by the value of money eighty years ago in 1932. However, this Court cannot
    modify the said range of penalties because that would constitute judicial legislation. What the
    legislature's perceived failure in amending the penalties provided for in the said crimes cannot be
    remedied through this Court's decisions, as that would be encroaching upon the power of
    another branch of the government. This, however, does not render the whole situation without
    any remedy. It can be appropriately presumed that the framers of the Revised Penal Code (RPC)
    had anticipated this matter by including Article 5, which reads:
    ART. 5. Duty of the court in connection with acts which should be repressed but which are not
    covered by the law, and in cases of excessive penalties. - Whenever a court has knowledge of any
    act which it may deem proper to repress and which is not punishable by law, it shall render the
    proper decision, and shall report to the Chief Executive, through the Department of Justice, the
    reasons which induce the court to believe that said act should be made the subject of penal
    legislation.

    There is an opinion that the penalties provided for in crimes against property be based on
    the current inflation rate or at the ratio of ₱1.00 is equal to ₱100.00 . The opinion advanced by
    Chief Justice Maria Lourdes P. A. Sereno echoes the view that the role of the Court is not merely
    to dispense justice, but also the active duty to prevent injustice. Thus, in order to prevent
    injustice in the present controversy, the Court should not impose an obsolete penalty pegged
    eighty three years ago, but consider the proposed ratio of 1:100 as simply compensating for
    inflation. Furthermore, the Court has in the past taken into consideration "changed conditions" or
    "significant changes in circumstances" in its decisions.

    With due respect to the opinions and proposals advanced by the Chief Justice and my
    Colleagues, all the proposals ultimately lead to prohibited judicial legislation. Short of being
    repetitious and as extensively discussed above, it is truly beyond the powers of the Court to
    legislate laws, such immense power belongs to Congress and the Court should refrain from
    crossing this clear-cut divide.

    Considering that the amount of ₱98,000.00 is ₱76,000.00 more than the ₱22,000.00
    ceiling set by law (Art. 315, RPC), then, adding one year for each additional ₱10,000.00, the
    maximum period of 6 years, 8 months and 21 days to 8 years of prision mayor minimum would
    be increased by 7 years. Taking the maximum of the prescribed penalty, which is 8 years, plus an
    additional 7 years, the maximum of the indeterminate penalty is 15 years.

    Applying the Indeterminate Sentence Law, since the penalty prescribed by law for the
    estafa charge against petitioner is prision correccional maximum to prision mayor minimum, the
    penalty next lower would then be prision correccional in its minimum and medium periods.
    Thus, the minimum term of the indeterminate sentence should be anywhere from 6 months and 1
    day to 4 years and 2 months.

    The Court should give Congress a chance to perform its primordial duty of lawmaking.
    The Court should not pre-empt Congress and usurp its inherent powers of making and enacting
    laws. While it may be the most expeditious approach, a short cut by judicial fiat is a dangerous
    proposition, lest the Court dare trespass on prohibited judicial legislation.

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