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NOE S. ANDAYA v. PEOPLE

This case has been cited 8 times or more.

2015-08-19
CARPIO, J.
We agree with the trial court that petitioner cannot be held liable for more than the amount stated in the Information. The Information only charged petitioner with estafa through falsification of commercial documents for the amount of P855,995. The allegations of facts constituting the offense charged are substantial matters, and the right of the accused to question his or her conviction based on facts not alleged in the Information cannot be waived.[24] Thus, petitioner can only be held liable for P855,995, and not the P2,074,326 proved by the prosecution.
2015-01-21
LEONEN, J.
Ricalde pleaded not guilty during his arraignment on August 21, 2002.[6]  The prosecution presented the victim (XXX),[7] his mother, and the medico-legal as witnesses, while the defense presented Ricalde as its sole witness.[8]
2012-04-11
BERSAMIN, J.
Nonetheless, in all criminal prosecutions, the Prosecution bears the burden to establish the guilt of the accused beyond reasonable doubt. In discharging this burden, the Prosecution's duty is to prove each and every element of the crime charged in the information to warrant a finding of guilt for that crime or for any other crime necessarily included therein.[14] The Prosecution must further prove the participation of the accused in the commission of the offense.[15] In doing all these, the Prosecution must rely on the strength of its own evidence, and not anchor its success upon the weakness of the evidence of the accused. The burden of proof placed on the Prosecution arises from the presumption of innocence in favor of the accused that no less than the Constitution has guaranteed.[16] Conversely, as to his innocence, the accused has no burden of proof,[17] that he must then be acquitted and set free should the Prosecution not overcome the presumption of innocence in his favor.In other words, the weakness of the defense put up by the accused is inconsequential in the proceedings for as long as the Prosecution has not discharged its burden of proof in establishing the commission of the crime charged and in identifying the accused as the malefactor responsible for it.
2009-07-13
CARPIO MORALES, J.
In Andaya v. People,[13] the Court expounded on the constitutional right to be informed of the nature and cause of the accusation against the accused.
2008-04-30
AUSTRIA-MARTINEZ, J.
It is a well-entrenched rule that appeal in criminal cases opens the whole case wide open for review.[20]
2007-09-28
YNARES-SANTIAGO, J.
The rule is that a variance between the allegation in the information and proof adduced during trial shall be fatal to the criminal case if it is material and prejudicial to the accused so much so that it affects his substantial rights.[29] In a prosecution for violation of B.P. 22, the time of the issuance of the subject check is material since it forms part of the second element of the offense that at the time of its issuance, petitioner knew of the insufficiency of funds. However, it cannot be said that petitioner was prejudiced by such variance nor was surprised by it. Records show that petitioner knew at the time he issued the check that he does not have sufficient funds in the bank to cover the amount of the check. Yet, he proceeded to issue the same claiming that the same would only be shown to prospective suppliers, a defense which is not valid.
2007-09-21
CHICO-NAZARIO, J.
In Andaya v. People,[21] this Court said:It is fundamental that every element constituting the offense must be alleged in the information. The main purpose of requiring the various elements of a crime to be set out in the information is to enable the accused to suitably prepare his defense because he is presumed to have no independent knowledge of the facts that constitute the offense. The allegations of facts constituting the offense charged are substantial matters and an accused's right to question his conviction based on facts not alleged in the information cannot be waived. No matter how conclusive and convincing the evidence of guilt may be, an accused cannot be convicted of any offense unless it is charged in the information on which he is tried or is necessarily included therein. To convict him of a ground not alleged while he is concentrating his defense against the ground alleged would plainly be unfair and underhanded. The rule is that a variance between the allegation in the information and proof adduced during trial shall be fatal to the criminal case if it is material and prejudicial to the accused so much so that it affects his substantial rights.
2006-09-15
YNARES-SANTIAGO, J.
Although the offense charged in the information is estafa through falsification of commercial document, appellant could be convicted of falsification of private document under the well-settled rule that it is the allegations in the information that determines the nature of the offense and not the technical name given in the preamble of the information. In Andaya v. People,[35] we held:From a legal point of view, and in a very real sense, it is of no concern to the accused what is the technical name of the crime of which he stands charged. It in no way aids him in a defense on the merits. x x x That to which his attention should be directed, and in which he, above all things else, should be most interested, are the facts alleged. The real question is not did he commit a crime given in the law some technical and specific name, but did he perform the acts alleged in the body of the information in the manner therein set forth. x x x The real and important question to him is, "Did you perform the acts alleged in the manner alleged?" not, "Did you commit a crime named murder?" If he performed the acts alleged, in the manner stated, the law determines what the name of the crime is and fixes the penalty therefor. x x x If the accused performed the acts alleged in the manner alleged, then he ought to be punished and punished adequately, whatever may be the name of the crime which those acts constitute. The elements of falsification of private document under Article 172, paragraph 2[36] of the Revised Penal Code are: (1) that the offender committed any of the acts of falsification, except those in paragraph 7, Article 171; (2) that the falsification was committed in any private document; and (3) that the falsification caused damage to a third party or at least the falsification was committed with intent to cause such damage.[37]