Dimat v. People

G.R. No. 181184 (January 25, 2012)

Mel Dimat was convicted for selling a stolen Nissan, failing to recognize its dubious documentation.

Facts:

The case involves Mel Dimat, who was charged with violating the Anti-Fencing Law (Presidential Decree No. 1612) in connection with the sale of a stolen vehicle. The facts of the case began in December 2000 when Samson Delgado, along with Jose Mantequilla and police officers, testified that Delgado purchased a 1997 Nissan Safari from Dimat for P850,000. The vehicle was purportedly sold with a deed of sale that included an engine number (TD42-126134) and a chassis number (CRGY60-YO3553).

On March 7, 2001, police officers from the Traffic Management Group (TMG) spotted the Nissan Safari in Quezon City, which bore a suspicious plate number. Upon inspection, they discovered that the actual engine number was TD42-119136 and the chassis number was CRGY60-YO3111, which matched a vehicle reported stolen from its registered owner, Jose Mantequilla. Mantequilla confirmed that his Nissan Safari had been carnapped on May 25, 1998, from Robinsons Galleria's parking area.

Dimat, in his defense, claimed he was unaware of Mantequilla and asserted that he had purchased the vehicle in good faith from a certain Manuel Tolentino, who had provided a deed of sale with the engine and chassis numbers that did not match the stolen vehicle. Dimat contended that the vehicle he sold to Delgado was not the same as the one reported stolen.

The Regional Trial Court (RTC) found Dimat guilty of violating the Anti-Fencing Law and sentenced him to imprisonment and ordered him to pay damages. The Court of Appeals (CA) affirmed the RTC's decision but modified the penalty.

Legal Issues:

The primary legal issue in this case is whether the Court of Appeals correctly ruled that Dimat knowingly sold the Nissan Safari, which was earlier carnapped from Mantequilla, thereby constituting a violation of the Anti-Fencing Law.

Arguments:

  • Prosecution's Argument: The prosecution argued that the elements of fencing were satisfied: a theft had occurred, Dimat sold the stolen vehicle, and he knew or should have known that the vehicle was derived from a crime. The prosecution pointed out that the vehicle Dimat sold had the same engine and chassis numbers as the stolen vehicle, indicating that he was aware of its illicit origin.

  • Defense's Argument: Dimat's defense was centered on the claim of good faith. He argued that he purchased the vehicle from Tolentino, who provided documentation that he believed was legitimate. Dimat maintained that he had no knowledge of the vehicle being stolen and that the discrepancies in the engine and chassis numbers were not his fault. He also contended that the lack of criminal intent should absolve him of liability under the Anti-Fencing Law.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decision of the Court of Appeals, emphasizing that the elements of fencing were present in this case. The Court reiterated that the Anti-Fencing Law does not require proof of criminal intent, as it is considered malum prohibitum. The prosecution must only establish that the accused knew or should have known that the item was derived from theft or robbery.

The Court found that Dimat's defense was flawed for several reasons:

  1. The vehicle sold to Delgado had the same engine and chassis numbers as the one reported stolen, contradicting Dimat's claim that he sold a different vehicle.
  2. Dimat's assertion that he was unaware of the vehicle's illicit nature was undermined by the fact that he received no proper documentation from Tolentino, which should have raised suspicions about the vehicle's legitimacy.
  3. The Court noted that Dimat's failure to verify the vehicle's documentation before selling it indicated a lack of due diligence, which further supported the conclusion that he should have known the vehicle was stolen.

Significant Legal Principles Established:

  1. The elements of fencing under the Anti-Fencing Law include the requirement that the accused knows or should have known that the item was derived from theft or robbery.
  2. Violations of the Anti-Fencing Law are considered malum prohibitum, meaning that intent is not a necessary element for conviction.
  3. The importance of due diligence in transactions involving the sale of vehicles, particularly in verifying ownership and documentation, is underscored.