- Petitioner
- Ramoncita O. Senador
- Respondent
- People
- Citation
- G.R. No. 201620
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Velasco, Jr., J.
- Decided
- March 6, 2013
Whether error in designation of offended party in Information violates accused's constitutional right to be informed of nature and cause of accusation
Summary
Senador was charged with estafa for receiving jewelry worth P705,685 under trust receipt agreement and failing to return items or remit sale proceeds. She argued that error in Information naming Cynthia Jaime as offended party when Rita Jaime filed complaint violated her constitutional right to be informed of charges. The Supreme Court affirmed her conviction, ruling that for crimes against property where subject matter is specifically identifiable (as opposed to generic property like money), errors in designating offended party are immaterial formal defects that do not prejudice substantial rights. The Court distinguished cases involving generic property where such errors are fatal from those involving specific identifiable property where they are harmless. The conviction was upheld but exemplary damages reduced from P100,000 to P30,000.