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SHEALA P. MATRIDO v. PEOPLE

FACTS:

Sheala Matrido was employed as a credit and collection assistant at Empire East Land Holdings, Inc. Her duties included collecting payments from real estate buyers and remitting them to the company in Makati City. On June 10, 1999, Matrido received a payment of P22,470.66 from a buyer named Amante dela Torre. However, she only remitted P4,470.66 to the company, resulting in a discrepancy of P18,000. The company conducted an investigation and discovered that Matrido failed to remit payments from other clients as well. As a result, the company filed various complaints against her, including a complaint for estafa. In October 2000, Matrido made partial payments totaling P162,000 to the company but was still charged with qualified theft for failing to fully cover her liability of P400,000. Matrido pleaded not guilty during her arraignment. Following the trial, she was convicted by the Regional Trial Court of Makati and sentenced to a prison term of ten years and one day to twelve years, five months, and ten days. The Court of Appeals upheld the trial court's decision. Matrido filed a petition arguing that her conviction violated her right to be informed of the nature and cause of the accusation against her because the prosecution attempted to prove estafa instead of qualified theft.

ISSUES:

  1. Whether or not the petitioner's right to be informed of the nature and cause of the accusation against her was violated.

RULING:

  1. The court ruled that the petitioner's right to be informed of the nature and cause of the accusation against her was not violated. The court explained that it is the allegations in the Information that determine the nature of the offense, not the technical name given by the public prosecutor in the preamble of the Information. The court further explained that the 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. Therefore, even if the prosecution was trying to prove estafa during trial, the petitioner's conviction for qualified theft is still valid as long as the elements of qualified theft were properly alleged in the information.

PRINCIPLES:

  • The constitutional right to be informed of the nature and cause of the accusation against the accused requires that every element constituting the offense must be alleged in the information.

  • It is the allegations in the Information that determine the nature of the offense, not the technical name given by the public prosecutor in the preamble of the Information.

  • The 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.