Title
Gonzales vs. Serrano
Case
G.R. No. L-25791
Decision Date
Sep 23, 1968
Complainant alleged estafa over a P10,172 plastic flower sale; parties novated C.O.D. to credit, reducing liability to civil. Court upheld fiscal's discretion, no criminal liability.
A

Case Digest (G.R. No. L-25791)

Facts:

Carlos B. Gonzales, the complainant, filed with the office of the City Fiscal of Manila a charge for estafa against Librada S. Asis, the respondent, sometime after November 17, 1964. The charge stemmed from a transaction in which Asis allegedly bought assorted plastic flowers and leaves from Gonzales on October 27, 1964 for a total of P10,172.00. Gonzales claimed the agreement was C.O.D., with Asis paying P2,000 cash and the balance P8,172.00 by EBC Check No. B.C. 907516; however, Asis later returned to ask that the check not be deposited because she had insufficient funds, and Gonzales allegedly agreed. Gonzales further alleged that he waited until November 17, 1964 for Asis to make a partial payment by accepting P5,556.00 as evidenced by a receipt, such that she had paid a total of P7,556.00, leaving a balance of P2,612.00. Asis, on the other hand, maintained that the parties agreed that items unsold could be returned and that she was ready and willing to return them, thereby negating criminal liability and indicating a civil obligation rather than estafa. During preliminary investigation, the prosecutor reported that the parties’ post-delivery conduct suggested novation: Asis requested that the check not be encashed the following day, and Gonzales accepted partial payment and issued a receipt reflecting a changed arrangement to pay the balance later. The City Fiscal approved the recommendation to drop the complaint on the ground that the obligation was civil in nature, and Gonzales’s appeal to the Secretary of Justice was denied. Gonzales then instituted an action for mandamus in the Court of First Instance of Manila to compel the City Fiscal to file an information for estafa, but the trial court dismissed his petition, and the case proceeded by direct appeal.

Issues:

Whether mandamus lies to compel the City Fiscal of Manila to file an information for estafa against Asis despite the City Fiscal’s determination during preliminary investigation that the matter involved only a civil obligation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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