G.R. No. 207418 - Barlin vs. People

Petitioner Rosella Barlin and complainant Ruth S. Gacayan were involved in a business relationship centered on the distribution of Triumph and Avon products.
The parties entered into agreements wherein Barlin received products through Trust Receipt Agreements (TRAs) with the obligation to either sell the products and remit the proceeds or return any unsold items.

Only TRAs No. 0081 and 0083 were signed directly by Barlin.
The remaining TRAs were signed by her salespersons, Margie Castillo and Eva Varga, raising issues on whether these had her authorization.

The TRAs clearly stated that Barlin was to hold the products in trust, dispose of or sell them, and remit the proceeds (less her commission) to Gacayan.
In the event the goods were not sold within the prescribed period or upon demand, Barlin was obligated to return the items to Gacayan.
Complications arose when Barlin failed to pay for certain items on time and issued post-dated checks which eventually bounced because they were drawn on a closed account.

Gacayan testified that after Barlin’s store was damaged by fire, she allowed Barlin to purchase merchandise on credit under the TRAs.
Gacayan claimed that Barlin owed a substantial amount (initially claimed as P74,955.00, later reduced to P24,975.00 by the Court of Appeals) resulting from failure to remit proceeds or return unsold goods.
Gacayan’s presentation relied notably on the TRAs and testimony from her saleslady, Gina Taberna, regarding the transactions executed by Castillo and Varga.

Barlin contended that only the TRAs personally signed by her (0081 and 0083) should bind her, arguing that the ones signed by her salespersons were unauthorized.
She pointed out that offsetting transactions—namely, the procurement of Avon merchandise from her—should be taken into account.
Barlin also admitted to a separate criminal case for violation of BP 22, where a compromise agreement was executed but claimed this should mitigate her criminal liability in the estafa case.

The Regional Trial Court (RTC) of Pasig City, Branch 151, in its May 10, 2006 Decision, convicted Barlin of estafa under Article 315(1)(b) of the Revised Penal Code (RPC).
The Court of Appeals (CA) later affirmed the conviction, modifying the computation of Barlin’s liability to P24,975.00, but maintained her criminal liability for the TRAs she personally endorsed and the offense of estafa.
After Barlin’s Motion for Reconsideration, the CA rendered a June 10, 2013 Amended Decision adjusting the minimum penalty to six (6) months and one (1) day of prision correccional and maintaining the orders for indemnification and payment of costs.

Whether the Court of Appeals erred in ruling that the agreements between Barlin and Gacayan constituted trust receipt agreements.

Barlin contended that certain TRAs were not executed by her hand and should not be deemed as binding trust receipt agreements.

Whether the Court of Appeals erred in convicting Barlin of an offense not specifically stated in the Information.

Barlin argued that the information did not clearly describe the offenses for which she was prosecuted, thus raising issues on the sufficiency and specificity of the charges.

Whether the Court of Appeals erred in convicting Barlin of estafa when it was not proven and established beyond reasonable doubt.

Barlin maintained that the evidence, especially regarding the TRAs not personally signed by her, was insufficient to prove the crime of estafa beyond reasonable doubt.