SAYOC v.

PEOPLE
G.R. No. 157723. April 30, 2009

FACTS:

Jaen was aboard a bus when a fellow passenger announced a hold-up. Three persons
then proceeded to divest the passengers of their belongings. Under knife-point, purportedly
Santos, Jaen’s necklace was taken by Santos cohort Almadin. Sayoc, meanwhile, reportedly
threatened to explode the hand grenade he was carrying if anybody would move. Thereafter,
the trio alighted from the bus. PO1 Terte (police officer), a passenger in the same bus, ran
after the trio, upon hearing somebody shouting about a hold-up. Sayoc was found by the
police officer hiding in an owner-type jeep. The latter instructed Jaen to guard Sayoc while
she pursued the two robbers. Sayoc was then brought to the police station as well as Santos
and Almadin a few hours later.

ISSUE:

Whether or not Sayoc et. al were guilty of highway robbery

RULING:

Yes. Based on the testimonies of the complainant and PO1 Remedios Terte, the accused
were clearly and positively identified as the three men who staged the robbery/ hold-up inside
the California bus. The variance in the testimonies of the prosecution witnesses is too trivial
to affect their credibility. Inaccuracies may in fact suggest that the witness is telling the truth
and has not been rehearsed as it is not to be expected that he will be able to remember every
single detail of an incident with perfect or total recall.
 TANZO v. DRILON
G.R. No. 106671. March 30, 2000

FACTS:

In February 1989, while he was in U.S.A., Mario offered Tanzo to invest in his and
brother Manuel’s transporting business, and promised returns of investment to Tanzo. When
Tanzo returned to the Philippines, the same offer was provided by Manuel. Eventually
convinced by the representations and assurances, Tanzo agreed to invest the total amount
of $34,000. Upon the expiration of the investment period, Tanzo demanded from Mario and
Manuel the proper accounting of his financial investment and/or the return of his capital
plus interest earned. At the outset, both avoided their obligation to Tanzo by making various
excuses but Manuel admitted that their shipments had encountered some problems with the
Bureau of Customs. Later, Tanzo discovered that the boxes had actually contained smuggled
goods and were seized in favor of the government.
When the brothers continued to ignore Tanzo’s demand for the return of his money,
Tanzo filed a complaint-affidavit for estafa against them.

ISSUE:

Whether or not private respondents Mario and Manuel were guilty of estafa

RULING:

No. It is found that Tanzo’s evidence is insufficient to support his charge of estafa. A
judicious scrutiny of the evidence on record shows that the transactions between private
respondents, particularly, Mario, were simple loans, and did not constitute a trust
agreement, the violation of which would hold the private respondents liable for estafa.