Facts:

The case involves Lucia Manuel y Cadiz (petitioner) as the accused and the People of the Philippines as the respondent. The events leading to the case began in November 2005 in San Rafael, Bulacan, where the petitioner allegedly committed the crime of Estafa as defined under Article 315, paragraph 2(d) of the Revised Penal Code (RPC). An Information was filed on July 27, 2007, charging the petitioner with Estafa for issuing ten checks totaling P889,606.00 against her account at the Philippine National Bank (PNB), Sta. Maria Branch, knowing that her account was closed at the time of issuance. The checks were issued in payment for live chickens ordered from Ebot's Farm, owned by Flordeliza Uy, who was the complainant in the case. The checks were dishonored upon presentment due to the account being closed, and despite several demands for payment, the petitioner failed to settle the amounts.

During the trial, the prosecution presented witnesses, including employees of Ebot...

Facts:

Background of the Case:
The case involves Lucia Manuel y Cadiz (petitioner) who was charged with Estafa under Article 315, paragraph 2(d) of the Revised Penal Code (RPC). The charges stemmed from the issuance of 10 postdated checks in November 2005, which were dishonored due to "Account Closed." The total amount of the checks was P887,606.00, allegedly issued to Flordeliza Uy (private complainant) in payment for live chickens purchased from Ebot's Farm.

Prosecution's Version:

• Flordeliza Uy was allegedly the owner of Ebot's Farm.
• Petitioner ordered live chickens and issued postdated checks in Uy's name as payment.
• Upon presentment, the checks were dishonored because the account was closed.
• Despite demands, petitioner failed to make good on the checks, causing damage to Uy.

Defense's Version:

• Petitioner denied defrauding Uy, claiming she never transacted with her.
• She asserted that the checks were issued in connection with orders from Ebot's Farm, which she believed was owned by Alex Uson, not Uy.
• Petitioner admitted issuing blank checks, leaving the payee name and amount blank, and trusted the farm's employee, Artates, to fill them out.
• She highlighted that Uy was never presented as a witness during the trial.

Issue:

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Ruling:

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Ratio:

1. Elements of Estafa:

   • The elements of Estafa under Article 315, paragraph 2(d) are: (1) the offender issued a check in payment of an obligation; (2) at the time of issuance, the offender had no funds or insufficient funds in the bank; and (3) the payee was defrauded.
   • The prosecution failed to prove deceit and damage, as Uy admitted she had no transactions with petitioner, and the underlying obligation was questionable.

2. Affidavit of Desistance:

   • Uy's Affidavit of Desistance, coupled with her testimony, explicitly repudiated the existence of any demandable obligation and raised serious doubts about petitioner's guilt.
   • The Court considered the affidavit and testimony as special circumstances that cast reasonable doubt on the prosecution's case.

3. Failure to Present Uy:

   • The prosecution’s failure to present Uy as a witness weakened its case, as her testimony was crucial to establishing the elements of deceit and damage.
   • The conflicting testimonies of the prosecution's witnesses and Uy's statements rendered the case highly dubious.

4. Extinguishment of Civil Liability:

   • The civil liability ex delicto was extinguished since Uy admitted there was no obligation between her and petitioner, and the act imputed to petitioner did not exist.

5. Reasonable Doubt:

   • The totality of the evidence, including Uy's desistance and contradictory testimonies, created reasonable doubt as to petitioner’s guilt, warranting her acquittal.