G.R. No. 189081 - Dy vs. People

Gloria S. Dy was General Manager of Mandy Commodities Company, Inc. (MCCI).
In May 1996, she proposed to President William Mandy the purchase of Pantranco property, leading Mandy to secure a ₱20,000,000 loan from International China Bank of Commerce (ICBC).

MCCI executed a chattel mortgage over warehouses as security; Dy was entrusted to manage loan repayments.
Upon default and notice of foreclosure in February 1999, Mandy gave Dy 25 “payable to cash” checks totaling ₱21,706,281 to prevent foreclosure, instructing her to apply them to the ICBC loan.
Dy testified she encashed the checks and returned the proceeds to Mandy; ICBC ultimately foreclosed for nonpayment.

In October 2002, MCCI filed an estafa complaint; an information was lodged against Dy in March 2004.
RTC Manila (Nov. 11, 2005) acquitted Dy for failure to prove misappropriation or conversion beyond reasonable doubt, finding the transaction a loan contract; nonetheless, it ordered her to pay ₱21,706,281 in civil liability.
On appeal, the Court of Appeals (Feb. 25, 2009) affirmed the civil liability award, ruling that acquittal on reasonable doubt does not preclude civil liability if preponderance of evidence warrants it.

Whether civil liability ex delicto may be awarded in a criminal estafa case when the accused is acquitted for lack of proof beyond reasonable doubt.
Whether a contractual obligation (civil liability ex contractu) falls within the “mandatory fusion” of criminal and civil actions under the Rules of Court.