G.R. Nos. 207220-21. March 16, 2022
ERIC WU A.K.A. WU CHUN AND DAPHNY CHEN, PETITIONERS, VS. PEOPLE OF THE PHILIPPINES AND HAFTI TOURS, INC., RESPONDENTS.

FACTS

Petitioners Eric Wu and Daphny Chen, Taiwan nationals residing in the Philippines, sought to transfer their dollar time deposit investment with the Philippine Retirement Authority (PRA) to respondent HAFTI Tours, Inc. (HTI) as a capital contribution in exchange for shares of stock. Pending PRA approval, HTI issued a board resolution authorizing the spouses Wu, among others, to deposit and withdraw from HTI’s corporate bank accounts. After the PRA deposited the peso equivalent (P4,622,508.00) into HTI’s account, HTI failed to issue the promised shares. The relationship deteriorated, and the spouses Wu issued checks from HTI’s accounts.
Two Informations for Estafa under Article 315(1)(b) of the Revised Penal Code were filed against the spouses Wu. Criminal Case No. 06-1263-CFM involved a check for P17,524.00 issued to Manila Montessori Children’s School Foundation Inc. for their son’s tuition. Criminal Case No. 07-0254-CFM involved a check for P291,000.00. Previously, HTI had filed seven criminal complaints before the Parañaque City Prosecutor involving the same checks, which were dismissed on the ground of duplicity of offenses. This dismissal was affirmed with finality by the Department of Justice, the Court of Appeals, and the Supreme Court in G.R. No. 196066.
The spouses Wu filed motions to quash the Informations in the Regional Trial Court (RTC). In Criminal Case No. 06-1263-CFM, they argued the facts did not constitute an offense and raised a prejudicial question. In Criminal Case No. 07-0254-CFM, they argued duplicity of offenses, as the check for P17,524.00 was already the subject of a prior prosecution (Criminal Case No. 03-1293 before RTC Parañaque, Branch 195). The RTC Branches 112 and 114 separately granted the motions to quash, both on the ground of duplicity of offenses, noting the prior prosecution for the same checks which had been dismissed with finality. HTI appealed to the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in granting HTI’s consolidated appeals and reversing the RTC Orders which quashed the Informations for Estafa on the ground of duplicity of offenses.

RULING

The Supreme Court granted the petition, reversed the Court of Appeals Decision and Resolution, and reinstated the RTC Orders quashing the Informations. The Court held that the ground for the motions to quash was duplicity of offenses, specifically that the same acts (issuance of the same checks for P291,000.00 and P17,524.00) had been the subject of a prior prosecution that was dismissed with finality. The RTC correctly quashed the Informations. The Court found that the CA erred in treating the motions as based on a different ground (that the facts alleged did not constitute an offense) and in ruling on the merits of the estafa charge. The proper course was to quash the Informations due to the prior final dismissal for duplicity of offenses, which barred a second prosecution for the same acts. The reinstated RTC Orders dismissed the criminal cases.