Title
Echaus vs. Court of Appeals
Case
G.R. No. L-41176
Decision Date
Jan 17, 1985
Rodolfo Echaus is convicted of estafa for issuing postdated checks without sufficient funds, defrauding a corporation of P6,760, with the Supreme Court affirming the conviction.
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Case Digest (G.R. No. L-41176)

Facts:

  • Rodolfo Echaus is the petitioner against the Honorable Court of Appeals and the People of the Philippines.
  • The events occurred between November 8 and November 12, 1962, in Manila.
  • Echaus was charged with estafa in Criminal Case No. 71522.
  • He allegedly induced Philrem Electrical and Auto Supply, Inc. to sell electrical appliances worth P6,760.00 by making false representations.
  • Echaus claimed to be the authorized purchasing agent for the Sea Breeze Hotel, owned by his brother.
  • He issued two post-dated checks as payment, knowing he lacked sufficient funds to cover them.
  • The checks were dishonored for "refer to drawer."
  • The trial court found Echaus guilty and sentenced him to an indeterminate penalty of six months to one year, eight months, and twenty-one days, along with an order to indemnify the complainant.
  • Echaus's demurrer to the evidence was denied, and he waived his right to present evidence.
  • The Court of Appeals affirmed the trial court's judgment, prompting Echaus to file a petition for review on certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied Echaus's petition for lack of merit.
  • The decision of the Court of Appeals and the trial court...(Unlock)

Ratio:

  • The Supreme Court determined that the prosecution's evidence sufficiently proved Echaus's guilt for estafa.
  • Although the letter from the Sea Breeze Hotel was considered hearsay, the focus was on Echaus's fraudulent misrepresentation to Bicharra, the sales manager of Philrem.
  • Echaus misled Bicharra into believing he was authorized to make purchases, ...continue reading

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