Case Digest (G.R. No. 111656)
Facts:
- Petitioner: Manuel L. Manahan, Jr.
- Respondents: Court of Appeals and the People of the Philippines.
- Events:
- On May 10, 1976, Manahan entered into an Equipment Lease Agreement with IFC Leasing and Acceptance Corporation (IFC) for an Isuzu dump truck.
- Lease terms included a 36-month period with a monthly rental of P3,541.20 and an initial deposit of P24,000.00.
- On September 16, 1976, a second lease agreement was made for a Kimco Hough JH65CN Payloader for 48 months at a monthly rental of P5,311.80.
- Complaint:
- IFC filed a complaint on March 15, 1977, for unpaid rentals totaling P160,110.18 (dump truck) and P249,975.44 (payloader).
- The court ruled in favor of IFC on April 3, 1978, but IFC did not execute the decision immediately.
- Demand and Charges:
- On June 23, 1981, IFC demanded the return of the equipment.
- Manahan failed to return the dump truck, leading to an estafa charge filed on March 15, 1983.
- Trial Court Decision:
- The Regional Trial Court of Makati found Manahan guilty of estafa on July 27, 1989, sentencing him to an indeterminate penalty and ordering indemnification to IFC.
- Appeal:
- Manahan appealed, but the Court of Appeals affirmed the decision with a penalty modification on May 21, 1993.
- Supreme Court Review:
- Manahan sought a review from the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court acquitted Manahan of the crime of estafa.
- The Supreme Court held Manahan civilly liable for the value of the lost dump truck amounting to P55,000...(Unlock)
Ratio:
- Violation of Lease Contract:
- Manahan violated the lease contract by subletting the dump truck without IFC's consent, but this did not constitute estafa.
- Elements of Estafa:
- The essential elements include receipt of personal property with an obligation to return it, conversion or misappropriation of the property, injury to another, and a demand for return.
- Lack of Criminal Intent:
- Manahan's default on returning the truck and efforts to recover it from the sublessee, Gorospe, negated the criminal intent required for estafa.
- Estafa requires criminal intent, which was not present in this case.
- Civil Liability:
- Manahan&...continue reading
Case Digest (G.R. No. 111656)
Facts:
The case involves petitioner Manuel L. Manahan, Jr., and respondents, the Court of Appeals and the People of the Philippines. On May 10, 1976, Manahan entered into an Equipment Lease Agreement with IFC Leasing and Acceptance Corporation (IFC) for an Isuzu dump truck. The lease was for 36 months with a monthly rental of P3,541.20 and an initial deposit of P24,000.00. Another lease agreement was made on September 16, 1976, for a Kimco Hough JH65CN Payloader for 48 months at a monthly rental of P5,311.80. IFC filed a complaint for a sum of money, replevin, and damages against Manahan on March 15, 1977, due to unpaid rentals amounting to P160,110.18 and P249,975.44 for the dump truck and payloader, respectively. The court ruled in favor of IFC on April 3, 1978, but IFC did not pursue execution of the decision. Instead, on June 23, 1981, IFC demanded the return of the equipment. Manahan failed to return the dump truck, leading to an estafa charge filed on March 15, 1983. The Regional Trial Court of Makati found Manahan guilty of estafa on July 27, 1989, sentencing him to an indeterminate penalty and ordering him to in...