Case Digest (G.R. No. 75920)
Facts:
The People of the Philippines v. Teresita S. Singson, G.R. No. 75920, November 12, 1992, Supreme Court Second Division, Campos, Jr., J., writing for the Court.
The case arises from commercial transactions between private corporate seller Sucrex Marketing Corporation (Sucrex) and Teresita S. Singson (the accused). On August 4, 1976, after an introduction by Rene Antonio, Singson purchased 1,000 bags of sugar from Sucrex at P74.50 per bag and paid by two postdated checks (dated August 7 and August 11, 1976), which were honored. On August 9, 1976, she bought an additional 4,000 bags at P75.00 per bag; Sucrex issued twenty sets of delivery orders and advice in triplicate, the originals to the buyer for presentation to the warehouse upon delivery.
To pay for the 4,000 bags, Singson issued six checks, five postdated. Only two of the six were honored; four checks (Exhs. E, F, G and H) totaling P200,000.00 were dishonored on presentment. The four checks were returned repeatedly (deposited and dishonored three times) and on the fourth attempt were returned under the "BAP rule" against a fourth redeposit. Upon learning of the dishonors in September 1976, Singson offered seven replacement checks (Exhs. J, J-1 to J-6) totaling P200,000.00, which Sucrex accepted; however, three of these replacement checks were subsequently dishonored with the bank stamp “Try next clearing.” Sucrex thereafter did not present the remaining replacements.
On September 14, 1976, Sucrex demanded payment. Singson visited Sucrex, explained that sudden adverse sugar price fluctuations prevented timely sale of the sugar and collection from her buyers, and offered partial payment. Sucrex initially refused but on October 12, 1976 accepted P30,000.00 in cash and the return of 92 bags; Sucrex’s receipt (Exh. L) expressly stated that acceptance “shall not in any way novate your obligation to Sucrex Marketing Corporation under our sale to you of 4,000 bags . . . .” Singson did not fund the outstanding checks.
An information was filed on March 11, 1980 in the Court of First Instance of Rizal at Pasig charging Singson with estafa by deceit under Article 315 of the Revised Penal Code, as amended by P.D. 818, alleging she induced Sucrex to sell 4,000 bags of sugar by issuing six checks she knew were unsupported; the information alleged damage to Sucrex in the amount of P200,000.00. After trial the court (the trial court) found the accused guilty as charged, sentenced her to reclusion perpetua (applying the penalty scheme in Art. 315 as then in force to reach the maximum penalty) and ordered indemnification of Sucrex....(Subscriber-Only)
Issues:
- Was the accused’s guilt of estafa proven beyond reasonable doubt?
- Can the prima facie presumption of deceit under Article 315 (from post-dating or issuing checks without funds and failing to deposit within three days) be overcome by surrounding circumstances such as prompt offers of replacement checks, partial pay...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)