Case Digest (G.R. No. 230669) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In July 2004, in Buenavista, Guimaras, Rex Sorongon (petitioner) borrowed a cement mixer valued at ₱25,000.00 from complainant Nelly Van der Bom for use in an Iloilo City project, promising to return it upon demand. When petitioner failed to return the mixer despite Nelly’s formal demand letter, she sought redress at the barangay in March 2005. During those proceedings, the parties executed an amicable settlement by which Nelly waived her ownership of the mixer (and other claimed unpaid accounts) in favor of petitioner on condition that no future countercharges be filed. Petitioner later submitted this settlement to the NLRC, which deducted the mixer’s value from its award in his favor. In January 2006, an Information was filed in the RTC, Branch 65, San Miguel, Jordan, Guimaras, charging Sorongon with Estafa under Article 315, paragraph 1(b) of the Revised Penal Code for misappropriating the mixer. He pleaded not guilty; following trial, the RTC (July 25, 2011) convicted him an... Case Digest (G.R. No. 230669) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Trial
- In July 2004, petitioner Rex Sorongon allegedly borrowed a cement mixer valued at ₱25,000.00 from Nelly Van der Bom under an express obligation to return it upon demand.
- An Information was filed in January 2006 in RTC Branch 65, San Miguel, Jordan, Guimaras, charging him with Estafa under Article 315(1)(b) of the RPC.
- Petitioner pleaded not guilty; trial on the merits ensued.
- Prosecution Evidence
- Nelly Van der Bom testified she lent the mixer after a water‐system project and sent demand letters when it was not returned.
- Francisco Igpuara (mechanic), Arnaldo Marcasote and Daren Almarquez (employees) and Bernaros Gregorios (former owner) corroborated that petitioner borrowed the mixer and failed to return it.
- Defense Evidence
- Barangay Kagawad Rudy de la Torre testified that in March 2005 the parties settled amicably before the barangay, covering unpaid accounts—including the mixer—and agreed no further charges or counterclaims would be filed.
- Petitioner denied borrowing the mixer, presented the amicable settlement to the NLRC in a labor case, and allowed deduction of the mixer’s value from his award.
- Lower Court Rulings
- RTC (July 25, 2011) convicted petitioner of Estafa under Art. 315(1)(b), sentencing him to prision correccional to prision mayor.
- CA (October 25, 2016) affirmed: held a contract of commodatum existed, failure to return upon demand constituted misappropriation, and amicable settlement did not extinguish criminal liability.
- CA Resolution (February 21, 2017) denied petitioner’s motion for reconsideration.
Issues:
- Whether the lower courts erred in convicting petitioner of Estafa under Article 315(1)(b) of the RPC given the prior amicable settlement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)