Case Digest (G.R. No. 134120) Core Legal Reasoning Model
Facts:
The case of People of the Philippines vs. Lea Sagan Juliano (G.R. No. 134120) arose from allegations of Estafa against Juliano, based on a series of transactions involving dishonored checks. On July 27, 1991, Juliano purchased 190 bags of rice from JCT Agro-Development Corporation for ₱89,800. She issued Check No. 142254, postdated to July 30, 1991, drawn against the Philippine Commercial International Bank. However, when the check was presented for encashment, it was dishonored due to insufficient funds. Julianna later issued two replacement checks, also drawn against the same bank, for ₱50,000 and ₱39,800 on August 20 and 22, 1991, respectively, which were also dishonored for the same reason.
Upon receiving notification of the dishonored checks, Juliano attempted to make amends by issuing replacement checks and executing a promissory note outlining a payment plan totaling ₱89,800. She made a partial payment of ₱10,000; however, this was rejected since it was incomplete. Follo
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Case Digest (G.R. No. 134120) Expanded Legal Reasoning Model
Facts:
# Transaction and Issuance of Checks
- On July 27, 1991, appellant Lea Sagan Juliano purchased 190 sacks of milled rice worth P89,800 from JCT Agro-Development Corporation (JCT) in Isulan, Sultan Kudarat.
- She issued a postdated check (PCIB Check No. 142254) dated July 30, 1991, drawn against the Philippine Commercial International Bank (PCIB), Isulan Branch, to pay for the rice.
- The check was dishonored upon presentation due to insufficient funds.
# Replacement Checks
- After being informed of the dishonor, appellant issued two replacement checks:
- PCIB Check No. 145452 dated August 20, 1991, for P50,000.
- PCIB Check No. 145454 dated August 22, 1991, for P39,800.
- Both replacement checks were also dishonored for insufficient funds.
# Demand and Promissory Note
- JCT sent a demand letter to appellant on August 31, 1991, which she received on September 6, 1991.
- Appellant executed a promissory note on September 10, 1991, promising to pay JCT in installments totaling P89,800.
- She made a partial payment of P10,000, which JCT rejected for being short by P10,000. No further payments were made.
# Trial Court Decision
- The trial court found appellant guilty of Estafa under Article 315, paragraph 2(d) of the Revised Penal Code for issuing the first check (PCIB Check No. 142254).
- She was also found guilty of violating Batas Pambansa Bilang 22 (Bouncing Checks Law) for issuing the two replacement checks.
- The trial court sentenced her to imprisonment and ordered her to pay JCT P89,800.
# Appeal to the Court of Appeals
- Appellant appealed her conviction for Estafa to the Court of Appeals, which upheld the trial court’s decision and referred the case to the Supreme Court due to the penalty of reclusion perpetua.
Issues:
- Whether appellant could be found guilty of Estafa under Article 315, paragraph 2(d) of the Revised Penal Code in the absence of proof beyond reasonable doubt that she employed deceit or false pretenses.
- Whether appellant’s failure to deposit the amount of the dishonored check within three days of notice constitutes prima facie evidence of deceit.
- Whether appellant could be convicted of Estafa for the dishonor of the replacement checks, which were issued to pay a pre-existing obligation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court acquitted appellant of Estafa due to the prosecution’s failure to prove deceit beyond reasonable doubt. However, her civil liability to JCT for the value of the rice was upheld.
- After being informed of the dishonor, appellant issued two replacement checks:
- PCIB Check No. 145452 dated August 20, 1991, for P50,000.
- PCIB Check No. 145454 dated August 22, 1991, for P39,800.
- Both replacement checks were also dishonored for insufficient funds.
# Demand and Promissory Note
- JCT sent a demand letter to appellant on August 31, 1991, which she received on September 6, 1991.
- Appellant executed a promissory note on September 10, 1991, promising to pay JCT in installments totaling P89,800.
- She made a partial payment of P10,000, which JCT rejected for being short by P10,000. No further payments were made.
# Trial Court Decision
- The trial court found appellant guilty of Estafa under Article 315, paragraph 2(d) of the Revised Penal Code for issuing the first check (PCIB Check No. 142254).
- She was also found guilty of violating Batas Pambansa Bilang 22 (Bouncing Checks Law) for issuing the two replacement checks.
- The trial court sentenced her to imprisonment and ordered her to pay JCT P89,800.
# Appeal to the Court of Appeals
- Appellant appealed her conviction for Estafa to the Court of Appeals, which upheld the trial court’s decision and referred the case to the Supreme Court due to the penalty of reclusion perpetua.
Issues:
- Whether appellant could be found guilty of Estafa under Article 315, paragraph 2(d) of the Revised Penal Code in the absence of proof beyond reasonable doubt that she employed deceit or false pretenses.
- Whether appellant’s failure to deposit the amount of the dishonored check within three days of notice constitutes prima facie evidence of deceit.
- Whether appellant could be convicted of Estafa for the dishonor of the replacement checks, which were issued to pay a pre-existing obligation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court acquitted appellant of Estafa due to the prosecution’s failure to prove deceit beyond reasonable doubt. However, her civil liability to JCT for the value of the rice was upheld.
- The trial court found appellant guilty of Estafa under Article 315, paragraph 2(d) of the Revised Penal Code for issuing the first check (PCIB Check No. 142254).
- She was also found guilty of violating Batas Pambansa Bilang 22 (Bouncing Checks Law) for issuing the two replacement checks.
- The trial court sentenced her to imprisonment and ordered her to pay JCT P89,800.