G.R. No. 73271 - Spouses Vintola vs. Insular Bank of Asia and America

Parties and Transaction
On August 20, 1975, Spouses Tirso and Loreto Vintola (the Vintolas) doing business as "Dax Kin International," applied for and were granted a domestic letter of credit in the amount of P40,000.00 by Insular Bank of Asia and America (IBAA), Cebu City.
The Letter of Credit authorized IBAA to negotiate drafts drawn by the Vintolas' supplier, Stalin Tan, on Dax Kin International for the purchase of puka and olive seashells.
The Vintolas jointly and severally agreed to pay the bank, at maturity and in Philippine currency, the amount drawn or paid under the credit plus usual charges.

Trust Receipt Agreement and Delivery of Goods
On the same day, August 20, 1975, the Vintolas received puka and olive shells worth P40,000.00 from Stalin Tan.
The Vintolas executed a Trust Receipt agreement with IBAA, agreeing to hold the goods in trust as the bank’s property with the liberty to sell them for the bank's account and to remit proceeds if sold. The due date was October 19, 1975.

Default, Criminal Action, and Civil Case
The Vintolas defaulted on their obligation. On January 1, 1976, IBAA demanded payment. The Vintolas offered to return the goods; IBAA refused acceptance.
IBAA filed estafa charges for alleged misappropriation, misapplication, and conversion of goods. The Vintolas deposited the goods with the trial court during criminal proceedings.
On April 12, 1982, the Court of First Instance acquitted the Vintolas, finding no misappropriation or conversion. It recognized that the bank’s remedy for default was civil, not criminal.
IBAA then filed a civil action to recover the value of the goods. The Regional Trial Court initially dismissed the complaint, finding it barred by the criminal acquittal; upon reconsideration, the court ordered the Vintolas to pay P72,982.27 plus interest, service charges, attorney’s fees, and costs.

Appeal and Contentions of the Vintolas
The Vintolas appealed, asserting that the acquittal in the estafa case barred the civil action because IBAA had not expressly reserved the civil action and had participated actively as private prosecutor, thereby filing the civil action impliedly with the criminal case under Section 1, Rule III of the 1985 Rules on Criminal Procedure.
They argued the acquittal judgment declared the non-existence of facts from which civil liability might arise, thus extinguishing the civil action under Section 3-b of Rule III of the same Rules.
The Vintolas further argued that since they could not dispose of the shells and deposited them with the court, their obligation has been extinguished.

Whether the acquittal in the estafa case bars the filing of a civil action for collection filed by IBAA.
Whether the civil action for recovery of the value of goods secured by a trust receipt is distinct and independent from the criminal estafa action.
Whether surrendering the goods and depositing them with the court extinguishes the Vintolas’ obligation to pay IBAA.