GR 75579; (September, 1991) (Digest)
G.R. No. 75579 September 30, 1991
Tomas Trinidad, petitioner, vs. The Court of Appeals, respondent.
FACTS
Petitioner Atty. Tomas Trinidad, as administrator of the estate of Nicolai Drepin and manager of Mother Earth Realty Development Corporation, was charged with violating Section 25 of P.D. 957 (The Subdivision and Condominium Buyers’ Protective Decree) for failing to deliver the title to a subdivision lot to buyer Francisca Dimabuyu upon her full payment of the purchase price. The prosecution established that Dimabuyu fully paid for Lot No. 19, Block 51 of Munting Baguio Village Subdivision through installments, as evidenced by receipts. Despite repeated demands, Trinidad failed to deliver the certificate of title, offering excuses such as unpaid taxes and currency devaluation adjustments. The Regional Trial Court convicted Trinidad, a decision affirmed by the then Intermediate Appellate Court.
ISSUE
Whether petitioner Tomas Trinidad is criminally liable for violation of P.D. 957 for non-delivery of the title to the buyer after full payment, considering his role as an administrator of an estate involved in probate proceedings.
RULING
The Supreme Court REVERSED the appellate court’s decision and ACQUITTED Trinidad. The Court’s ruling hinged on the absence of criminal intent (mens rea), a necessary element for the crime. Trinidad, as administrator of Drepin’s estate, could not legally transfer the title without prior authorization from the probate court overseeing the estate settlement. P.D. 957 mandates delivery of title upon full payment, but this presupposes the seller has the present legal capacity to transfer ownership. Here, the property was part of judicial custody. If Trinidad had delivered the title without probate court approval, he would have violated his fiduciary duty and disregarded the court’s jurisdiction. Thus, he was caught in a legal dilemma not of his own making. His failure to deliver was due to a legal impediment, not a willful refusal, thereby negating criminal intent. The Court emphasized that while the buyer may seek relief through civil remedies against the estate, criminal liability cannot attach under these specific circumstances.