People vs.

Brillantes, 671 SCRA 388, April 25, 2012

FACTS: Jose Brillantes and Saturnino de la Cruz was charged with illegal sale of shabu and illegal
possession of dangerous drug of shabu under Sections 5 and 11, Article II of RA 9165 entitled An Act
Instituting the Comprehensive Dangerous Drugs Act Of 2002. When arraigned, both the accused pleaded
not guilty of the crimes charged. The RTC held that the prosecution successfully discharged the burden of
proof in the cases of illegal sale and illegal possession of dangerous drugs. The trial court relied on the
presumption of regularity in the performance of duty of the police officials who conducted the buy-bust
operation. The appellate court found no reason to depart from the ruling of the trial court. It upheld that
all the elements of the offense of illegal sale and illegal possession of drugs were present and the finding
against Brillantes and Dela Cruz were well established by the prosecution. A Notice of Appeal was filed
by Brillantes through counsel before the Supreme Court. His co-accused De la Cruz, did not appeal his
conviction. While this case is pending appeal, the accused-appellant Brillantes died while committed at
the Bureau of Correction.

ISSUE: Whether or not the criminal liability of Brillantes is extinguished by his death.

HELD: Yes. It is plain that both the personal penalty of imprisonment and pecuniary penalty of fine of
Brillantes were extinguished upon his death pending appeal of his conviction by the lower courts. There is
no civil liability involved in violations of the Comprehensive Dangerous Drugs Act of 2002. No private
offended party is involved as there is in fact no reference to civil liability in the decision of the trial court.
Moreover, the appeal of Brillantes culminating in the extinguishment of his criminal liability does not
have any effect on his co- accused De la Cruz who did not file a notice of appeal. The Rules on Criminal
Procedure (Section 11, Rule 122) on the matter states that an appeal taken by one or more of several
accused shall not affect those who did not appeal, except insofar as the judgment of the appellate court
is favorable and applicable to the latter. The extinguishment of Brillantes criminal and pecuniary
liabilities is predicated on his death and not on his acquittal. Following the provision, the appeal taken by
Brillantes and subsequent extinguishment of his liabilities is not applicable to De la Cruz.

D'Aigle vs. People, 675 SCRA 206, June 27, 2012

FACTS: Petitioner DAigle is charged with Estafa before the RTC. Petitioner was the former managing
director of Samfit Philippines, Inc. (SPI) tasked with the management of the company as well as the
management, care and custody of SPIs personal properties. At the time that he was holding said position,
petitioner was likewise a majority stockholder of TAC Manufacturing Corporation (TAC), an entity
engaged in the fabrication of wire bending machine similar to that being used by SPI. Sometime in
November 1996, petitioner was divested of his duties and responsibilities as SPIs managing director due
to alleged conflict of business interest. Because of this, Parducho, the current president of SPI, conducted
an audit and inventory of SPIs properties and reviewed its financial statements, vouchers, books of
account and other pertinent records. He also interviewed some of SPIs employees. These revealed that
several properties of SPI such as wire materials, electronic transformer, electronic and computer boxes,
machine spare parts, while still under the management, care and custody of petitioner, went missing and
were left unaccounted for. Further investigation revealed that some of SPIs wire bending machines,
computer and electronic boxes were inside the premises of TAC. This was confirmed by Daniel
Gutierrez, a former employee of TAC, who likewise admitted that TAC copied the wire bending
machines of SPI.

In a letter, SPIs counsel formally demanded upon petitioner to turn over to SPI all its equipment under
his care and custody. Ignoring the demand, petitioner was thus indicted with the present case. SPI also
filed a replevin case against him for the recovery of the electronic and computer boxes. Subsequently, and
by virtue of the Writ of Replevin, an electronic box found inside TACs premises was recovered from
petitioner while a computer box was later on surrendered to the Sheriff. RTC found that the prosecution
had established the guilt of petitioner for the crime of Estafa. However, trial courts Decision did not
expressly mention that he was found guilty beyond reasonable doubt of the crime charged.

ISSUE: Whether or not a judgment is rendered defective because of the absence of a declaration of guilt
beyond reasonable doubt in the dispositive portion.

HELD: NO. A judgment is not rendered defective just because of the absence of a declaration of guilt
beyond reasonable doubt in the dispositive portion. The ratio decidendi of the RTC Decision extensively
discussed the guilt of the petitioner and no scintilla of doubt against the same was entertained by the
courts below. Indeed, petitioners guilt was duly proven by evidence of the prosecution. In any event, a
judgment of conviction, pursuant to Section 2, Rule 120 of the Rules of Court, is sufficient if it states: "1)
the legal qualification of the offense constituted by the acts committed by the accused and the aggravating
or mitigating circumstances which attended its commission; 2) the participation of the accused in the
offense, whether as principal, accomplice or accessory; 3) the penalty imposed upon the accused; and 4)
the civil liability or damages caused by his wrongful act or omission to be recovered from the accused by
the offended party, if there is any, unless the enforcement of the civil liability by a separate civil action
has been reserved or waived." The Court finds that all of these are sufficiently stated in the trial courts
Decision.