G.R. No. L-30896 - Sia vs. People

Procedural History
Trial Court (Court of First Instance, Manila) convicted petitioner Jose O. Sia of estafa under Article 315(1)(b) of the Revised Penal Code for breach of a trust receipt agreement.
The Court of Appeals affirmed the conviction (Rollo [CA], pp. 103–104).
Petitioner filed a petition for review with the Supreme Court.

Underlying Transaction
Petitioner, as President and General Manager of Metal Manufacturing of the Philippines, Inc. (MEMAP), applied on 31 May 1963 for L/C No. 63/109, opened 5 June 1963 for US$ 18,300 to import cold rolled steel sheets.
In July 1963 MEMAP received 150 M/T of steel sheets valued at ₱ 71,023.60, delivered by Continental Bank under a trust receipt agreement signed by petitioner between July and December 1963.
The trust receipt obligated petitioner to hold the goods in trust, sell them, and remit proceeds to the Bank to cover the acceptance and other indebtedness.
Despite demands dated 17 and 27 December 1963, petitioner allegedly failed to return the goods or account for proceeds; the unpaid balance amounted to ₱ 46,818.68 after forfeiture of a marginal deposit of ₱ 28,736.47.
Upon complaint by Continental Bank and preliminary investigation, an information was filed on 22 October 1964 charging estafa.

Corporate Officer Liability
Can a corporate officer (petitioner), acting on behalf of MEMAP, be held personally criminally liable for breach of the trust receipt agreement executed in the corporation’s name?

Nature of Trust Receipt Breach
Does violation of a trust receipt agreement constitute the crime of estafa under Article 315(1)(b) of the Revised Penal Code, or is it merely a civil breach of contract absent specific penal legislation?