Facts:

The case involves Rodolfo Echaus as the petitioner against the Honorable Court of Appeals and the People of the Philippines as respondents. The events leading to the case occurred between November 8 and November 12, 1962, in the City of Manila. Echaus was charged with the crime of estafa in Criminal Case No. 71522 before the Court of First Instance of Manila. The information alleged that Echaus, by means of false representations, induced Philrem Electrical and Auto Supply, Inc. to sell and deliver electrical appliances, including four GE water coolers and several Chromalox microtubes stoves, valued at P6,760.00. Echaus claimed to be the authorized purchasing agent of the Sea Breeze Hotel in Bacolod City, which was owned by his brother. He issued two post-dated checks as payment, knowing that he did not have sufficient funds in the bank to cover them when they matured. Upon presentation, the checks were dishonored for "refer to drawer." The trial court found Echaus g...

Facts:

Introduction and Initial Interaction

• Petitioner Rodolfo Echaus was charged with estafa in Criminal Case No. 71522 of the Court of First Instance of Manila.
• The information alleged that Echaus, from November 8 to November 12, 1962, defrauded Philrem Electrical and Auto Supply, Inc. by falsely representing himself as the authorized purchasing agent of the Sea Breeze Hotel in Bacolod City.
• Echaus induced Philrem to sell and deliver electrical items worth P6,760.00, paying with two postdated checks (Nos. PC 6236 and 6238) dated December 17, 1962, and November 30, 1962, respectively.
• Echaus knew he had insufficient funds in the bank, and the checks were dishonored upon presentation.

Transactions and Delivery of Goods

• Echaus was introduced to Miguel Bicharra, Philrem’s sales manager, by Jose Estregan. Echaus claimed to represent the Sea Breeze Hotel and inquired about purchasing electrical items for the hotel’s renovation.
• Bicharra initially hesitated but was convinced when Echaus mentioned his brother, Romeo Echaus, president of Cardinal Insurance Co., could vouch for him.
• On November 8, 1962, Echaus and Estregan visited Bicharra’s office, requesting electrical appliances for immediate shipment to Negros.
• Bicharra delivered the items and accepted postdated checks from Echaus, who claimed he would receive funds from the hotel soon.
• The checks were dishonored when presented to the bank, with notations "refer to drawer."

Demand and Investigation

• On December 20, 1962, Philrem sent a demand letter to the Sea Breeze Hotel. The hotel replied, denying Echaus’s authority to make purchases on its behalf.
• Bicharra and Estregan attempted to locate Echaus but failed, leading to the filing of the criminal case.
• Evidence showed Echaus deposited P1,330.00 on November 15, 1962, but withdrew it the same day. His bank balances on November 30 and December 17, 1962, were P28.69 and P23.69, respectively.

Trial Proceedings

• After the prosecution presented its evidence, Echaus filed a demurrer to the evidence, which was denied. He waived his right to present evidence, and the trial court found him guilty of estafa.
• The Court of Appeals affirmed the trial court’s decision, prompting Echaus to file this petition for review.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Hearsay Evidence (Exhibit "F")

   • While the Court of Appeals considered Exhibit "F" (the hotel’s denial letter) as hearsay, it ruled that this did not affect the outcome of the case. The prosecution’s other evidence sufficiently established Echaus’s misrepresentation and deceit.
   • The testimony of Miguel Bicharra and the dishonored checks (Exhibits "C" and "D") proved that Echaus falsely represented himself as the authorized agent of the Sea Breeze Hotel and issued checks knowing he had insufficient funds.

2. Elements of Estafa

   • The crime of estafa under Article 315, paragraph 2(a) requires:
     a. False pretenses or fraudulent acts.
     b. Inducement of the victim to part with property.
     c. Damage or prejudice to the victim.
   • Echaus’s actions satisfied all elements:
     • He falsely claimed to represent the Sea Breeze Hotel.
     • He induced Philrem to deliver goods by issuing postdated checks.
     • The checks were dishonored, causing Philrem a loss of P6,760.00.

3. Knowledge of Insufficient Funds

   • Echaus argued that Bicharra knew he lacked sufficient funds at the time of the transaction, negating deceit. However, the Court ruled that deceit was present because Echaus concealed his inability to cover the checks when they fell due.
   • The fact that Echaus withdrew his deposit on the same day he made it and had minimal bank balances on the check dates demonstrated his intent to defraud.

4. Postdated Checks as Evidence of Deceit

   • The issuance of postdated checks without sufficient funds, coupled with Echaus’s false representation, constituted deceit. The Court emphasized that Echaus’s actions were calculated to defraud Philrem, satisfying the elements of estafa.

Conclusion:

The Supreme Court upheld the conviction of Rodolfo Echaus for estafa, finding that his false representations and issuance of dishonored checks constituted deceit under Article 315 of the Revised Penal Code. The petition was denied for lack of merit.