- Petitioner
- People of the Philippines
- Respondent
- Virgie F. Dingal
- Citation
- G.R. No. 248374
- Court
- Supreme Court
- Decided
- September 28, 2022
Conviction for qualified theft and proper penalty imposition under amended Revised Penal Code
Summary
The Supreme Court affirmed the Court of Appeals' conviction of Virgie F. Dingal for qualified theft involving P4,750,494.96 stolen from University of Southern Philippines Foundation, Inc. The key issue was the proper penalty under the amended Revised Penal Code. The Court revised the penalty, applying RA 10951's adjusted property value thresholds for theft penalties. Since the stolen amount exceeded P2,200,000.00 and qualified theft requires a penalty two degrees higher due to grave abuse of confidence, the Court imposed reclusion perpetua without parole eligibility. The decision demonstrates the application of recent amendments to criminal penalty provisions and establishes precedent for calculating penalties under the revised theft provisions.
Focus of dispute
Conviction for qualified theft and proper penalty imposition under amended Revised Penal Code
Legal facts
Accused-appellant Virgie F. Dingal appropriated P4,750,494.96 from University of Southern Philippines Foundation, Inc. through qualified theft committed with grave abuse of confidence. The case involved theft exceeding P2,200,000.00 threshold under the amended penalty provisions of Republic Act No. 10951.
Judgement and reasoning
Court of Appeals (CA): Convicted accused-appellant of qualified theft in CA-G.R. CEB-CR No. 02784 dated November 24, 2017. Specific reasoning not detailed in the Supreme Court resolution.
Supreme Court (SC): Affirmed the conviction but revised the penalty. Applied Article 309 in relation to Article 310 of the Revised Penal Code as amended by RA 10951. Since the amount stolen (P4,750,494.96) exceeded P2,200,000.00, and considering qualified theft requires penalty next higher by two degrees due to grave abuse of confidence, imposed reclusion perpetua without eligibility for parole under RA 9346. Ordered payment of P4,750,494.96 with 6% interest per annum.