People v. Dizon

G.R. No. 120957 (August 22, 1996)

Facts:

The case involves Nita V. Dizon, who was charged with estafa under two informations and with violations of Batas Pambansa Blg. 22 in four informations. The events leading to the charges began in May 1985 when Dizon and her husband expressed interest in purchasing residential lots in Ayala Alabang through Susan Sandejas Gomez, a broker accredited by Ayala Corporation. The Dizon spouses indicated they had substantial financial resources, including a residential lot in Greenhills and a new car.

In December 1985, the Dizon spouses contacted Gomez to proceed with the purchase of two lots, and they issued a check for P40,000 as a reservation fee. By February 1986, Nita Dizon requested a loan from Gomez, claiming urgent financial needs for her business. After several persistent requests, Gomez agreed to lend Dizon P200,000 in cash and a P50,000 manager's check on February 14, 1986, in exchange for two postdated checks totaling P272,000.

Subsequently, on February 18, 1986, Dizon again requested cash, leading Gomez to provide an additional P180,000 in exchange for two more checks totaling P225,000. The checks were issued with blank amounts, which Gomez filled in later. When the checks were presented for encashment, they were dishonored due to insufficient funds. Dizon and her husband later claimed that Nita had been a victim of a hold-up, which prevented them from honoring the checks.

Gomez, feeling defrauded, sought legal recourse, leading to the filing of estafa charges against Dizon. The trial court convicted Dizon, sentencing her to significant prison terms and ordering her to indemnify Gomez. The Court of Appeals affirmed the conviction but increased the penalties.

Legal Issues:

1. Whether the trial court erred in finding that the transactions between Dizon and Gomez constituted estafa.
2. Whether the Court of Appeals erred in increasing the penalties imposed on Dizon.
3. Whether the transactions were usurious, thus absolving Dizon of liability.
4. Whether the informations filed against Dizon were defective for not specifying the penal clause.

Arguments:

For the Accused-Appellant (Dizon):

• Dizon contended that the trial court erred in its findings regarding the amounts received and the nature of the transactions.
• She argued that the checks were issued as part of a legitimate business transaction and that the amounts were not accurately represented.
• Dizon claimed that the transactions were usurious, and therefore, she was not legally obligated to honor the checks.
• She also asserted that the informations filed against her were defective for not specifying the penal clause of the law violated.

For the Plaintiff-Appellee (Gomez):

• Gomez maintained that she provided the amounts as loans to Dizon, who issued checks in return, which were subsequently dishonored.
• She argued that the evidence supported the trial court's findings regarding the amounts involved and the nature of the transactions.
• Gomez contended that the issue of usury was irrelevant since the Central Bank Circular No. 905 had effectively removed interest ceilings, making the transactions valid.
• She asserted that the informations were sufficient as they charged Dizon with estafa under the Revised Penal Code.

Court's Decision and Legal Reasoning:

The court upheld the findings of the trial court and the Court of Appeals, affirming Dizon's conviction. The court emphasized the credibility of Gomez's testimony, which was consistent and corroborated by evidence. The court noted that the trial court's findings of fact are generally respected unless there are significant overlooked facts.

The court rejected Dizon's argument regarding usury, clarifying that the Central Bank Circular had removed interest ceilings, thus making the transactions valid. The court also found that the informations were not defective, as they sufficiently charged Dizon with estafa under the Revised Penal Code without needing to specify the penal clause.

The court modified the penalties imposed by the Court of Appeals, increasing the sentences to thirty years of reclusion perpetua for the estafa charges, reflecting the gravity of the offenses.

Significant Legal Principles Established:

• The credibility of witnesses is paramount in determining the outcome of cases involving conflicting testimonies.
• Usury laws have been effectively rendered inoperative by Central Bank Circular No. 905, allowing parties to agree on interest rates without legal limitations.
• Informations in criminal cases do not need to specify penal clauses as long as they adequately inform the accused of the charges against them.