Scribd Logo
Upload

Welcome to Scribd!

  • 124 views

    Spouses Dulay v. People

    Uploaded by

    hello there
    Petitioners were convicted of estafa for selling a parcel of land to private complainants while falsely claiming ownership. They filed a motion to quash the charges, which was denied by the trial court. Both the trial court and appellate court found petitioners guilty, agreeing they sold the property through false pretenses about owning it. The Supreme Court upheld the conviction, finding petitioners made fraudulent misrepresentations to complete the sale despite not owning the land.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Spouses Dulay v. People

    Uploaded by

    hello there
    124 views1 page
    Petitioners were convicted of estafa for selling a parcel of land to private complainants while falsely claiming ownership. They filed a motion to quash the charges, which was denied by the trial court. Both the trial court and appellate court found petitioners guilty, agreeing they sold the property through false pretenses about owning it. The Supreme Court upheld the conviction, finding petitioners made fraudulent misrepresentations to complete the sale despite not owning the land.

    Original Title

    Spouses-Dulay-v.-People

    Copyright

    © © All Rights Reserved

    Available Formats

    DOCX, PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Petitioners were convicted of estafa for selling a parcel of land to private complainants while falsely claiming ownership. They filed a motion to quash the charges, which was denied by the trial court. Both the trial court and appellate court found petitioners guilty, agreeing they sold the property through false pretenses about owning it. The Supreme Court upheld the conviction, finding petitioners made fraudulent misrepresentations to complete the sale despite not owning the land.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    124 views1 page

    Spouses Dulay v. People

    Uploaded by

    hello there
    Petitioners were convicted of estafa for selling a parcel of land to private complainants while falsely claiming ownership. They filed a motion to quash the charges, which was denied by the trial court. Both the trial court and appellate court found petitioners guilty, agreeing they sold the property through false pretenses about owning it. The Supreme Court upheld the conviction, finding petitioners made fraudulent misrepresentations to complete the sale despite not owning the land.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    Spouses Dulay v. People of the Philippines G.R. No. 215132, September 13, 2021, (Hernando, J.

    Facts: Petitioners claimed ownership of a 450-square-meter parcel in Baguio City and sold it to private
    complainants, the couples Isabelo and Hilaria Dulos (Hilaria; collectively as spouses Dulos); hence,
    petitioners were charged with estafa under RPC Article 315 2(a).

    Petitioners filed a Motion to Quash before the arraignment, which the RTC refused. The RTC ruled that:
    (1) the trial court has jurisdiction to try the estafa matter under RFC Article 315 2(a), and (2) there is no
    other pending criminal case before the first level courts of Agoo, La Union that constitutes litis pendentia.
    As a result, petitioners pled not guilty during their arraignment.

    The RTC found petitioners guilty of Estafa under Article 315, (2)(a) of the RPC. The trial court ruled that
    all the elements of estafa by deceit under Article 315 (2)(a) of the RFC were established and proven by
    the prosecution beyond reasonable doubt.

    On appeal, the appellate court upheld the petitioners' conviction and expanded their responsibility for civil
    damages to include interest payments. The lower courts all agreed that petitioners sold the subject
    property to the Dulos spouses under false pretenses of ownership.

    Issue: Whether petitioners are guilty of the crime of Estafa when private complainants were aware that
    the subject property was not in their names at the time of the transaction.

    Ruling: There is no merit in petitioners' appeal.

    The lower courts determined that petitioners are not the owners, particularly the registered owners, of the
    subject property. Nonetheless, they plainly sold the property to the Dulos couples, which they do not
    possess under any circumstances. In fact, the vacillating justifications raised by the petitioners highlight
    their deception.

    First. Petitioners made false pretenses and fraudulent misrepresentations to complainants, the Dulos
    spouses, which included the following false claims.

    Second. The second, third, and fourth elements of the offense are also present, as determined by the
    lower courts.

    As demonstrated herein, petitioners committed estafa by deceit under Article 315 paragraph 2(a) of the
    RPC.

    You might also like