Case Digest (G.R. No. 48384)
Facts:
In Leonida C. Quinto v. People of the Philippines (G.R. No. 126712, April 14, 1999), the petitioner Leonida Quinto was indicted before the Regional Trial Court, Pasig City, Branch 157, for estafa under Article 315(1)(b) of the Revised Penal Code. On March 23, 1977, in Makati City, she received in trust jewelry worth ₱36,000.00 from private complainant Aurelia Cariaga to sell on commission and to return unsold items within five days. Quinto signed a receipt (Exhibit “A”) confirming her obligation. When the five-day period lapsed, she requested an extension but still failed to vend the pieces. Approximately six months later, Cariaga demanded their return through a formal letter, which Quinto ignored. The RTC, on January 25, 1993, found Quinto guilty beyond reasonable doubt of misappropriation and conversion of the entrusted property, sentencing her to seven years and one day to nine years of prision mayor and ordering indemnification of ₱36,000.00. The Court of Appeals affirmed onCase Digest (G.R. No. 48384)
Facts:
- Indictment and trial
- Leonida C. Quinto y Calayan was charged under Article 315(1)(b) of the Revised Penal Code for estafa for receiving in trust from Aurelia Cariaga jewelry valued at ₱36,000 on commission, with an obligation to return the jewelry or remit proceeds within five days.
- Upon arraignment on March 28, 1978, she pleaded not guilty and trial followed.
- Prosecution evidence
- Exhibit “A” (receipt) dated March 23, 1977, acknowledged receipt of one set of marques with brilliantitos (₱17,500), a 2.30-karat solo ring (₱16,000), and a rosetas ring (₱2,500).
- She failed to sell or return the jewelry within five days, obtained extensions, still did not comply, ignored a demand letter after six months, prompting estafa charges.
- Defense evidence
- Quinto claimed she was a jewelry trader introduced to Cariaga in 1975, citing prior installment sales to third parties (Mrs. Camacho and Mrs. Ramos) and direct payments by these buyers to Cariaga.
- She argued the original obligation was novated when Cariaga consented to installment payments by the buyers.
- Lower court decisions
- RTC (Branch 157, Pasig City) on January 25, 1993: found her guilty beyond reasonable doubt, sentenced her to 7 years and 1 day to 9 years of prision mayor, and ordered indemnity of ₱36,000.
- CA (Third Division) on September 27, 1996 (CA-G.R. CR No. 16567): affirmed the RTC judgment.
Issues:
- Whether the original commission agreement was novated by Cariaga’s alleged consent to direct installment payments from buyers, thereby extinguishing Quinto’s obligation.
- Whether Quinto’s failure to return or remit the entrusted jewelry or proceeds constitutes estafa under Article 315(1)(b) of the Revised Penal Code.
- Whether the evidence establishes guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)