People v. Jalandoni Case Analysis I.

Parties Petitioner: People of the Philippines Respondents: Teresa Jalandoni

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Prior Proceedings BPI filed a suit against respondent alleging that respondent has committed estafa. The trial court held that respondent was guilty beyond reasonable doubt of the crime of estafa and sentenced to a penalty of reclusion perpetua, to indemnify the BPI a certain amount as balance of the amount which she swindled from the said bank and to pay the costs. Respondent filed a motion to appeal where the court set aside the appealed judgment and another one is entered acquitting her of the charge. BPI filed a motion to modify the said judgment. Theories of the Parties Petitioner: that respondent should pay for her civil liability with interests at the legal rate from the filing of the civil until paid Respondent: that the amount of the civil liability, if any, is unsettled and requires necessarily the introduction of proof Objectives of the Parties Petitioner: to make the respondent pay for her civil liability with interests at the legal rate from the filing of the action until paid Respondent: to be not compelled of paying of her civil liability Key Facts BPI filed a suit against respondent alleging that respondent has committed estafa. The trial court held that respondent was guilty beyond reasonable doubt of the crime of estafa and sentenced to a penalty of reclusion perpetua, to indemnify the BPI a certain amount as balance of the amount which she swindled from the said bank and to pay the costs. Respondent filed a motion to appeal where the court set aside the appealed judgment and another one is entered acquitting her of the charge. BPI filed a motion to modify the said judgment. It invoked a CA decision where the court acquitted the accused of malversation of funds on the ground of reasonable doubt but nonetheless ordered her to pay the amount of her civil liability. Respondent opposed the said motion on the grounds that the CA decision it was invoking was under the OLD Rules of Court and therefore, not applicable at all in this case and the amount of civil liability, if any, is unsettled and requires necessarily the introduction of proof. Issue/s Whether or not respondents claim is valid

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Holding/ Finding No. Respondent is still liable to pay for her civil liability. The court said that the claim is utterly devoid of merit. Ratio Decidendi The Court said that the respondent admitted that the BPI suffered damage in the amount of P 1, 391, 780. 00. The fact that the respondent caused damage to BPI makes her liable for what she had caused. The Court stressed that for the respondent to assert that the civil liability, if any, is unsettled is an insult to the dignity of this Court. Disposition The motion to modify the former judgment is granted and that the accused was ordered to pay the amount with interest at the legal rate of 12% per annum from the filing of the action until paid.