G.R. No. L-48757 - Ganzon vs. Court of Appeals

On July 9, 1993, petitioner Adela Delgado entered into a money-changing transaction with private respondent Emmanuel Ang Jaranilla in Manila.
Delgado proposed the exchange of USD 74,000 for Philippine pesos, setting a conversion rate at PhP 27.43 per dollar.
Jaranilla consulted with his father, Manuel Ang, and agreed to the transaction, thereby establishing the basis for the deal.

Manuel Ang issued Metrobank Check No. 061224813 for the amount of PhP 2,029,820, payable to cash.
Jaranilla entrusted the check to his secretary, Fely Aquino (also known as Lily Ang), who was recognized by the bank under that name.
At the Binondo Metrobank branch, both Aquino and Delgado endorsed the check, after which Delgado received the peso amount from the bank teller.
Delgado subsequently claimed she needed to retrieve the dollars from her car, having no currency on her person at the time of encashment.

After receiving the PhP 2,029,820, Delgado failed to return with or deliver the promised USD 74,000.
Despite repeated demands by Jaranilla for the delivery of the dollars, Delgado absconded with the pesos, thereby breaching the agreed terms.
Jaranilla, operating in the money-changing business, filed a criminal complaint for estafa based on the ensuing fraudulent transaction.

The Regional Trial Court (RTC), Branch 54 in Manila, found Delgado guilty of estafa.
The trial court determined that Delgado’s false representations—asserting possession of the dollars—were made with the intent to defraud, inducing Jaranilla to part with PhP 2,029,820.
Delgado’s defense, which involved the testimony of a witness, Carina Alabado, claiming that she had delivered the dollars, was contradicted by the testimony of Fely Aquino.
Accordingly, the RTC convicted Delgado and sentenced her to twenty (20) years of reclusion temporal, along with an order to pay indemnity of PhP 2,029,820 plus compounded legal interest.

Both Jaranilla and Delgado appealed the RTC decision.
The Court of Appeals (CA) affirmed Delgado’s conviction but modified the sentence in conformance with the Indeterminate Sentence Law—ranging from a minimum of 4 years and 2 months of prision correccional to a maximum of 20 years of reclusion temporal.
The CA set the reckoning period for interest computation from the date of the transaction (July 9, 1993) and awarded additional remedies to Jaranilla, including:

The actual injured party should be Manuel Ang (the issuer of the check) rather than Jaranilla, with whom she transacted;
Her capacity as a money changer gave her the ability to possess the USD 74,000, thus negating fraudulent intent;
The testimony of Carina Alabado, who claimed to have delivered the dollars, should be given more weight than that of Aquino.

The Supreme Court assessed these arguments while primarily emphasizing the factual findings of the lower courts.

Whether Manuel Ang, as the source of the funds and issuer of the check, should be deemed the injured party, or whether the proper injured party is Jaranilla, who directly transacted with Delgado.

Whether Delgado’s assertion that, by virtue of her involvement in money-changing, she had the capacity to possess USD 74,000, impacts her liability for estafa.

Whether the conflicting testimonies of Fely Aquino and Carina Alabado affect the determination of fraud, particularly regarding the delivery of the dollars.
The extent to which appellate courts should defer to the trial court’s assessment of witness credibility.