(Freedom from excessive fines, cruel, degrading, or inhuman punishment)

Corpuz vs. People

G.R. No. 180016
29 April 2014

FACTS
 Corpuz and Tangcoy entered into an agreement where Corpuz will
 According to private complainant Danilo Tongcoy, he and the petitioner (Corpuz) met at
the Admiral Royale Casino is Olongapo City sometime in 1990.
 Private complainant (Tongcoy) was then engaged in a business of lending money to
casino players and petitioner (Corpuz) heared that Tongcoy had some jewelries for sale.
 Corpuz approached Tongcoy on May 2, 1991 and offered to sell the said jewelries on a
commission basis.
 Tongcoy agreed and turned over to the petitioner the following items with a total value
of 98,000 pesos
 According to Tongcoy, Corpuz signed a receipt. And they both agreed that the
Petitioner shall remit the proceed of the sale and/or, if unsold to return the same items,
within a period of 60 days.
 The period expired without the petitioner remitting the proceeds of sale or returning
the unsold jewelries.
 RTC found petitioner guilty beyond reasonable doubt of the Estafa under Article 315,
paragraph 1, subparagraph b of the RPC. (ruling: 4 years and 2 months of prision
correccional in its medium period as minimum to 14 years and 8 months of reclusion
temporal in its minimum period as the maximum. To indemnify the amount of 98,000 as
actual damage and to pay for the cost of suit.
 Case was elevated to the court of appeals. Petition was also denied. CA affirmed with
modification (indeterminate penalty of 4 years 2 months of prison correccional, as
minimum, to 8 years of prison mayor, as maximum, plus 1 year for each additional
10,000 pesos or a total of 7 years)

ISSUE

Whether or not there is a perceived injustice brought about by the range of penalties (excessive
fines) that the courts continue to impose against property committed today especially in estafa.

RULING
 The Court finds that there seems to be a perceived injustice brought about by the range
of penalties that the courts continue to impose on crimes against property committed
today, based on the amount of damage measured by the value of money eighty years
ago in 1932. However they cannot change the penalty provided by the legislators. They
can only act in virtue of Article 5 of the RPC which allows them only to report to the
President, thru the DOJ, penal laws which they deem excessive, or acts which they think
should be repressed but is not yet prohibited by law, and recommend that it be a
subject of legislation by the legislative.
 it is truly beyond the powers of the Court to legislate laws, such immense power
belongs to Congress and the Court should refrain from crossing this clear-cut divide.
With regard to civil indemnity, as elucidated before, this refers to civil liability which is
awarded to the offended party as a kind of monetary restitution. It is truly based on the
value of money. The same cannot be said on penalties because, as earlier stated,
penalties are not only based on the value of money, but on several other factors.
Further, since the law is silent as to the maximum amount that can be awarded and only
pegged the minimum sum, increasing the amount granted as civil indemnity is not
proscribed. Thus, it can be adjusted in light of current conditions.
 The penalty ordered by the CA is modified that the penalty imposed is the
indeterminate penalty of imprisonment ranging from THREE (3) YEARS, TWO (2)
MONTHS and ELEVEN DAYS of prision correccional, as minimum, to FIFTEEN (15) YEARS
of reclusion temporal as maximum.