G.R. No. L-35645 - People vs. V.M. Ruiz

Petitioner Antonio Nieva, Jr., an auto repair shop owner in Quezon City, was acquainted with Alberto Joven, a regular customer, and learned about idle construction equipment owned by the family of the late Atty. Ramon Joven.
Initially, a lease arrangement was contemplated for a Toyota dump truck, whereby petitioner proposed to repair the truck at his own expense with the repair costs to be deducted from the rental fees, to be used in a construction project.
During a meeting in Bacolor, Pampanga in 1985, negotiations evolved when Atty. Ramon Joven stipulated that the truck be repaired before accepting any lease terms.

On April 30, 1985, while the truck was still in petitioner’s custody (obtained originally for repair purposes), Atty. Joven, who was then confined at the Lung Center, authorized the transfer of the dump truck to petitioner.
A formal lease contract was executed on May 14, 1985; however, petitioner failed to perform his obligations as neither repair work was rendered nor rental payments made.
Upon learning of this non-performance, Atty. Joven visited petitioner’s shop to reclaim the truck, but petitioner countered by offering to purchase the vehicle.

The parties subsequently agreed on a sale: Atty. Joven quoted a price of P70,000.00 for the dump truck, which petitioner accepted.
An absolute deed of sale was executed on June 10, 1985, evidencing the transfer of the dump truck without an immediate demand for payment.
Approximately one week after the deed of sale, petitioner delivered a post-dated check (drawn on the Commercial Bank of Manila, Check No. 015417 dated July 31, 1985, for P70,000.00) to Atty. Joven as payment for the truck.
The check was eventually deposited at the Angeles City Branch of the Bank of the Philippine Islands but was dishonored because it was drawn against an account that had been closed.

Estafa under paragraph 2(d), Article 315 of the Revised Penal Code, for issuing a worthless check in payment for the dump truck.
Violation of Batas Pambansa Blg. 22, concerning the issuance of a check despite knowing insufficient funds.

At arraignment, petitioner pleaded “not guilty” to both charges.
After trial, the Regional Trial Court of Pampanga convicted petitioner in both cases, imposing imprisonment and fines as well as ordering indemnification of P70,000.00 to Atty. Joven.
Petitioner subsequently appealed the conviction to the Court of Appeals, which affirmed the trial court’s judgment.

The petitioner argued that the essential elements for estafa were not present, contending:

The post-dated check was issued after the execution of the deed of sale—thus in payment of a pre-existing obligation—and not as fraud or deceit at the time of contracting an obligation.
There was insufficient evidence of lack of funds at the time the check was drawn, as well as absence of actual damage.
The conviction was based solely on the testimony of Alberto Joven, which the petitioner described as biased, hearsay, and uncorroborated.

Additionally, petitioner questioned the jurisdiction of the Regional Trial Court of Pampanga, arguing that the events giving rise to the charges did not occur in Pampanga.

Whether the issuance of the post-dated check, being made one week after the execution of the deed of sale, constitutes the fraudulent act (i.e. the efficient cause of defraudation) for purposes of estafa under paragraph 2(d), Article 315 of the Revised Penal Code.
Whether the elements of estafa are satisfied given that the check was issued in payment of a pre-existing obligation rather than as a means to defraud.
Whether the evidence, particularly the testimony of the prosecution’s sole witness Alberto Joven, sufficiently establishes the timing and nature of the transaction for a conviction of estafa.
Whether the Regional Trial Court of Pampanga had proper jurisdiction over the criminal offenses charged, considering the locus of the check’s presentation and the transitory nature of the crimes.