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DAVID B. CAMPANANO v. JOSE ANTONIO A. DATUIN

FACTS:

David B. Campanano, Jr., the president of Seishin International Corporation, filed a complaint for Estafa against Jose Antonio Datuin. Datuin was convicted of Estafa by the Regional Trial Court and his appeal was dismissed by the Court of Appeals, rendering the decision final and executory.

Datuin then filed a complaint for Incriminating Against Innocent Persons against Campanano and another individual, arguing that the Estafa charge was false and malicious due to newly discovered evidence. This evidence was a cash voucher that proved Datuin had already paid for the roadrollers involved in the Estafa charge. Datuin explained that he had forgotten about the payment and did not have the cash voucher as evidence during the trial.

The Office of the City Prosecutor of Quezon City dismissed Datuin's complaint, claiming lack of jurisdiction and no basis to indict Campanano and the other person for the crime. They did not consider the cash voucher as evidence in their decision-making.

ISSUES:

  1. Whether the complaint for Incriminating Against Innocent Persons filed by respondent against petitioner and another person should be dismissed.

RULING:

  1. Yes, the complaint for Incriminating Against Innocent Persons should be dismissed. The Office of the City Prosecutor of Quezon City dismissed the complaint for lack of jurisdiction. Even if it had jurisdiction, there was no basis to indict the respondents for the crime imputed to them. The estafa case filed by Seishin International Corporation against respondent was found to have merit by the Regional Trial Court of Pasig City, and this decision was affirmed by the higher courts. The alleged newly discovered evidence, a cash voucher, did not change the fact that respondent was convicted of estafa. Therefore, the complaint for incriminating innocent persons is baseless and without factual or legal basis.

PRINCIPLES:

  • Jurisdiction determines which court or office has the authority to hear and decide a case.

  • A complaint may be dismissed if it lacks jurisdiction or if there is no basis to indict the respondents for the crime imputed to them.

  • Newly discovered evidence may not be sufficient to reverse a conviction if it does not change the merits of the case.