Title
Supreme Court
Diaz vs. People
Case
G.R. No. 208113
Decision Date
Dec 2, 2015
Petitioner acquitted of estafa but held civilly liable for P32,000 due to failure to remit proceeds or return goods, affirmed by SC with modified interest rates.

Case Digest (G.R. No. 208113)
Expanded Legal Reasoning Model

Facts:

  • Initiation of the Case and Underlying Transaction
    • An Information for estafa was filed on March 11, 1999, before the Regional Trial Court of Manila, Branch 5, against petitioner Dolores Diaz for her alleged failure to remit or return the proceeds from merchandise received on consignment.
    • Respondent Leticia S. Arcilla, a businesswoman engaged in selling goods through agents, claimed that she entrusted merchandise to petitioner under a consignment arrangement.
    • On February 20, 1996, respondent allegedly delivered umbrellas and bath towels to petitioner, with the transaction evidenced by an acknowledgment receipt bearing petitioner’s signature.
    • Despite the consignment, petitioner reportedly remitted only P3,300.00 on March 20, 1996, and thereafter failed to remit further proceeds or return the unsold merchandise.
  • Petitioner’s Defense and Contentions
    • Petitioner acknowledged previous business dealings with respondent but contended that such dealings were as a client purchasing purchase order cards (POCs) and gift checks (GCs) on an installment basis, not in an agency capacity.
    • She denied receiving merchandise worth P32,000.00 on February 20, 1996, claiming instead that she had merely signed blank documents (including two one-half sheets of paper and a trust receipt) as a safety precaution.
    • Petitioner maintained that her last transaction with respondent was settled in 1995, and she did not assume the responsibility of acting as an agent in a consignment or trust relationship.
  • Lower Court and Appellate Proceedings
    • The Regional Trial Court (RTC) rendered a Decision on June 29, 2011, acquitting petitioner of the criminal charge of estafa on the ground that no intent to defraud was established; however, it held her civilly liable to pay respondent P32,000.00 with interest from the filing date of March 11, 1999 until full satisfaction, plus the payment of court costs.
    • The Court of Appeals (CA) upheld the civil liability in its Decision dated January 30, 2013, ruling that the respondent had proven by preponderance of evidence:
      • The existence of a transaction evidenced by the acknowledgment receipt dated February 20, 1996.
      • Petitioner’s failure to remit the proceeds or return the unsold merchandise.
    • The CA rejected petitioner’s assertion regarding the alleged "blank documents," holding that such a claim was unsupported by evidence and merely amounted to an unsubstantiated allegation.
    • The CA modified the award of interest, computing it from the time of the extrajudicial demand (July 28, 1998), and directed petitioner to pay interest at a rate of six percent (6%) per annum until finality, and thereafter, at twelve percent (12%) per annum on the outstanding balance.
    • Petitioner’s motion for reconsideration was denied on July 10, 2013, prompting the filing of the petition for review on certiorari before the Supreme Court.
  • Evidentiary Basis and Transactional Dynamics
    • The key piece of evidence was the acknowledgment receipt dated February 20, 1996, which indicated that petitioner received the merchandise and implicitly assumed the obligation to remit the proceeds or return the unsold items by a given deadline.
    • The documentary evidence, supported by respondent’s testimonial and other displays of record, established the existence of the transaction and the consequent non-performance of petitioner’s duty.
    • The factual record underscored the distinction between the standards of proof in criminal cases (beyond reasonable doubt) versus civil cases (preponderance of evidence).

Issues:

  • Whether the Court of Appeals committed reversible error in holding petitioner Dolores Diaz civilly liable to respondent Leticia S. Arcilla for failing to remit the proceeds or return the unsold merchandise.
  • Whether the documentary evidence—specifically, the acknowledgment receipt dated February 20, 1996—sufficiently established the existence of the consignment transaction and petitioner's corresponding obligation.
  • Whether petitioner’s allegations regarding the signing of allegedly “blank documents” and her purported non-agency status have any probative value to rebut the evidence submitted by respondent.
  • Whether the imposition and computation of interest by the CA, including its modification from the extrajudicial demand, were appropriate under the applicable legal standards and evidentiary findings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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