G.R. No. 230527 - Pacific Ocean Manning, Inc. vs. Castillo

Petitioner Hur Tin Yang was charged in twenty-four (24) consolidated Informations dated March 15, 2002, with Estafa under Article 315, par. 1(b) of the Revised Penal Code (RPC) in relation to Presidential Decree No. 115 (PD 115), also known as the Trust Receipts Law.
The complainant was Metropolitan Bank and Trust Company (Metrobank), represented by its Officer in Charge, Winnie M. Villanueva.
The allegations stated that on or about May 28, 1998, petitioner, then an authorized officer of Supermax Philippines, Inc. (Supermax), received in trust from Metrobank reinforcing bars valued at P1,062,918.84 under trust receipts covered by Letter of Credit No. MG-LOC 216/98. Petitioner was obligated to hold the goods in trust and turn over the proceeds from their sale or return the unsold goods to Metrobank within a specified period.
However, petitioner allegedly failed and refused to comply with this obligation, misappropriating and converting the goods or their value for his own use, to the damage and prejudice of Metrobank.

Metrobank extended several commercial letters of credit to Supermax in 1998, which were used to pay for delivery of construction materials for Supermax’s projects.
Metrobank required petitioner, as Vice-President for Internal Affairs of Supermax, to sign twenty-four (24) trust receipts as security for these materials. Petitioner agreed to hold the materials or proceeds in trust for Metrobank.
When the trust receipts fell due, Supermax failed to pay or deliver the goods/proceeds despite demand letters dated August 15, 2000, and October 11, 2001. Metrobank then filed criminal complaints against petitioner.
Petitioner admitted signing the trust receipts but argued that the transaction was a simple loan secured by the trust receipts and that the materials were delivered prior to the signing. Additionally, Metrobank knew that the materials were for Supermax’s own use, not for resale.
Trial court found petitioner guilty of Estafa and sentenced him to an indeterminate penalty with civil liability to Metrobank amounting to Php13,156,256.51.

The Court of Appeals (CA) upheld the conviction, finding that failure to deliver proceeds or unsold goods under a trust receipt constitutes Estafa, a malum prohibitum offense, regardless of whether the goods were actually intended for sale.
Petitioner’s Motion for Reconsideration before the CA was denied.
Petitioner filed a petition for review before the Supreme Court, which was dismissed by Minute Resolution in 2012 for lack of reversible error.
Petitioner filed a Motion for Reconsideration before the Supreme Court, reiterating that the transactions were loans and not trust receipt transactions.

Whether petitioner Hur Tin Yang is liable for Estafa under Article 315, par. 1(b) of the Revised Penal Code in relation to PD 115 (Trust Receipts Law), despite evidence that the entruster bank Metrobank knew the goods covered by the trust receipts were never intended for resale but only for use in Supermax’s construction business.