G.R. No. 248584, August 30, 2023
Felix G. Valenzona, Petitioner, vs. The People of the Philippines, Respondent.

FACTS

Petitioner Felix G. Valenzona was the President of ALSGRO Industrial and Development Corporation (ALSGRO), a real estate company. ALSGRO entered into two Contracts to Sell with Ricardo B. Porteo on March 24, 2003, covering two subdivision lots. Porteo made payments until September 2003 but later defaulted. Upon verification, Porteo discovered that the contracts were not registered with the Register of Deeds, as required by Section 17 of Presidential Decree No. 957 (the Subdivision and Condominium Buyers’ Protective Decree), and that the lots had been sold to other buyers. Porteo’s demand for a refund was denied. A criminal Information was filed against Valenzona, in his capacity as President of ALSGRO, for willfully, unlawfully, and feloniously failing to register the transaction. Valenzona defended himself by stating that the registration of documents was not his function but was handled by ALSGRO’s Marketing, Documentations, and Processing Department, and that his role involved overseeing the business and signing documents. The Regional Trial Court (RTC) found Valenzona guilty beyond reasonable doubt, a decision affirmed by the Court of Appeals (CA). The CA held that Valenzona, as President, was criminally liable under Section 39 of P.D. 957, and that violations of this special law are mala prohibita, where criminal intent is immaterial.

ISSUE

Whether the Court of Appeals erred in affirming the RTC Decision finding Valenzona guilty beyond reasonable doubt for violating Section 17 of P.D. 957.

RULING

The Supreme Court granted the petition and reversed the decisions of the lower courts. The prosecution failed to establish Valenzona’s guilt beyond reasonable doubt. The Court held that while a violation of Section 17 of P.D. 957 by ALSGRO was established, the evidence was insufficient to prove Valenzona’s criminal liability as a corporate officer under Section 39. Section 39 of P.D. 957 imposes liability on “the president, vice-president, and other officers” who “have direct charge of, as well as responsibility for, the administration of the business” of the corporation. The Information specifically charged Valenzona with having “willfully, unlawfully and feloniously” failed to register the transaction. The prosecution, however, did not present evidence to show that Valenzona had “direct charge” or “responsibility for the administration” of the specific task of registering contracts, or that he willfully participated in or authorized the omission. Mere proof of his position as President is insufficient. Citing ABS-CBN v. Gozon, the Court emphasized that for a corporate officer to be held criminally liable, the prosecution must prove the officer’s active participation, direct responsibility, or at least negligence in the performance of duties leading to the violation. Since the prosecution relied solely on his corporate title and failed to prove his direct and active participation in the act constituting the offense, Valenzona’s guilt was not proven beyond reasonable doubt. He was acquitted on the ground of reasonable doubt.