Corpuz vs. People of the Philippines | G.R. No. 180016, April 29, 2014.
Doctrine:
Statutory Construction; View that in case of doubt in the interpretation or application of laws, it is presumed that the lawmaking body intended right and justice to prevail.—Article 10 of the Civil Code states: “In case of doubt in the interpretation or application of laws, it is presumed that the lawmaking body intended right and justice to prevail.” The Code Commission found it necessary to include this provision to “strengthen the determination of the Court to avoid an injustice which may apparently be authorized in some way of interpreting the law.” Corpuz vs. People, 724 SCRA 1, G.R. No. 180016 April 29, 2014
Facts:
Private complainant Danilo Tangcoy and the petitioner Lito Corpuz met at Admiral Royale Casino in Olongapo City. Petitioner heard about the business engagement of Danilo Tangcoy which involves lending money to casino players. At that time, the complainant has pieces of jewelry to sell hence the petitioner took the opportunity to offer the complainant that he will sell the pieces of jewelry which have an aggregate value of P98,000.00 on a commission basis. They agreed that the petitioner shall remit the proceeds within 60 days. Nonetheless, the period expired without any remittance from Lito Corpus. Upon meeting again for the second time, Lito corpus promised that he will pay the value of the said items entrusted to him but he failed to pay.
The complainant filed an estafa against the petitioner for the facts stated. However, Petitioner Corpuz argued that the receipt which serves as the proof submitted by Tangcoy is inadmissible for it is a mere photocopy. There is also inconsistency of information on the part of the complaint that the date of occurrence which is July 5, 1991, is materially different from the testification by the complainant which is May 2, 1991. Hence his testimony against him is not sufficient for conviction.
On January 28, 1992, the complainant Danilo Tangcoy was found guilty beyond reasonable doubt of the crime estafa. However, the case was elevated to the Court of appeals and later on denied for the reason of lack of merit. With this, according to the petitioner, the Court of Appeals erred in affirming the ruling of the Trial Court, admitting in evidence a receipt dated May 2, 1991, and its same sub markings, although the same was merely a photocopy thus it will violate the best evidence rule which says that the evidence should be original.
Issue: (1) Whether or not the photocopied document can serve as proof without violating the evidence rule. (2) Whether or not estafa is the right accusation against the petitioner.
Ruling:
(1)Yes. Supreme Court ruled: An information is legally viable as long as it distinctly states the statutory designation of the offense and the acts or omissions constitutive thereof. Then Section 6, Rule 110 of the Rules of Court provides that a complaint or information is sufficient if it states the name of the accused; the designation of the offense by the statute; the acts or omissions complained of as constituting the offense; the name of the offended party; the approximate time of the commission of the offense, and the place wherein the offense was committed.
With the lens of Statutory Construction, we can see that our duty is to interpret the law. It is a duty reposed on us by the Constitution. We provide meaning to law’s language and make laws written in a different historical context relevant to present reality.
Source: Corpuz vs. People, 724 SCRA 1, G.R. No. 180016 April 29, 2014.
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