Case Digest (G.R. No. 191240)
Facts:
Cristina B. Castillo v. Phillip R. Salvador, G.R. No. 191240, July 30, 2014, the Supreme Court Third Division, Peralta, J., writing for the Court.Petitioner Cristina B. Castillo filed criminal and civil complaints alleging that respondent Phillip R. Salvador (with his brother Ramon initially charged as co-accused) defrauded her of US$100,000.00 between March 2001 and May 2002 by inducing her to invest in a freight and remittance business to be operated under Phillip’s name in Hong Kong. The Information charged estafa under Article 315, par. 2(a) of the Revised Penal Code; upon arraignment the accused pleaded not guilty and trial ensued.
At trial petitioner testified to a close personal relationship with respondent, several promotional trips to Hong Kong, Bangkok and Palau, her role in registering Phillip Salvador Freight and Remittance International Limited in Hong Kong (December 27, 2001), and that she handed US$100,000.00 to Phillip in May 2002 as seed money for the business, witnessed by her half-brother Enrico Tan. She also admitted giving respondent other sums at various times and that she had asked for receipts in earlier, large loans but not for this alleged US$100,000.00, allegedly to avoid traces during pending annulment proceedings. Respondent and Ramon denied receipt of the US$100,000.00 and testified that the business never operated for lack of license, personnel and funds; they admitted other financial transactions and travel.
The Regional Trial Court (Branch 202, Las Piñas City) convicted Phillip Salvador of estafa on April 21, 2006 and ordered indemnity of US$100,000.00; Ramon Salvador was acquitted for insufficiency of evidence. Phillip appealed to the Court of Appeals (CA). On February 11, 2010 the CA, in CA-G.R. CR No. 30151, reversed the RTC and acquitted Phillip, concluding the prosecution failed to prove guilt beyond reasonable doubt. Petitioner brought the present petition for review on certiorari to the Supreme Court, attacking only the civil aspect (the ...(Pro-only)
Issues:
- Does a criminal acquittal based on reasonable doubt preclude civil liability arising from the same acts?
- Did petitioner prove by a preponderance of evidence that respondent is civilly liable for the loss of US$100,000.00 and entitle...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)