G.R. No. 127857 - De Jesus vs. Court of Appeals

In December 1986, complainant Mariano S. Macias saw a newspaper advertisement offering certain four-wheeler Isuzu trucks for sale.
After calling the advertised number, Macias conversed with accused Elbert Tan and subsequently arranged to meet at Tan’s premises.
Macias visited Tan’s warehouse in Pasay City, where he was shown two four-wheeler Isuzu trucks under assembly.
Tan represented that he was the owner of the trucks and was selling them.
The parties agreed that Macias would purchase one truck for P92,000.00, with P17,000.00 as a down payment and a second-hand school bus valued at P65,000.00 offered as a trade-in; an additional balance of P10,000.00 was to be paid upon delivery.

On December 15, 1986, Macias paid the P17,000.00 down payment and transferred the title of his school bus to Tan.
A supervising mechanic later expressed doubts regarding Tan’s ownership of the truck.
Upon verifying at the shop, Macias was informed by a foreman, Johnny, that the trucks were owned by a third party, not by Tan.
Tan initially promised to deliver the truck after being informed but subsequently failed to do so.
Macias’s repeated attempts to contact Tan were met with evasion and refusal.

During the preliminary investigation in the Office of the City Fiscal of Pasay City, Tan partially reimbursed Macias P22,000.00 and both parties executed a compromise agreement where Tan agreed to return P45,000.00 (instead of P65,000.00, representing the value of the trade-in school bus).
Due to the compromise agreement, the fiscal’s office initially dropped the estafa charge.
Later, Tan’s non-compliance with the terms of the compromise led to the filing of a formal criminal information for estafa against him.

In an Information dated February 29, 1988, Tan was charged with estafa under Article 315, Revised Penal Code, for defrauding Macias by falsely representing ownership of the truck.
During arraignment, Tan pleaded not guilty and trial ensued.
After the prosecution rested its case, Tan filed a Motion for Leave to File Demurrer to Evidence (dated July 25, 1988).
On July 29, 1988, the trial court warned that filing a demurrer to evidence constituted a waiver of the right to present evidence, and accordingly, the motion was not given leave.
Despite the warning, Tan proceeded to file the demurrer; once denied, his right to adduce further evidence was considered waived.
Tan’s subsequent motion for reconsideration was also denied.
On April 28, 1989, Tan was convicted of estafa. His appeal to the Court of Appeals was unsuccessful, prompting the petition for review.

Whether Tan, after filing a demurrer to evidence without express leave of court, effectively waived his right to adduce his own evidence.
Whether the trial court’s explicit warning regarding the waiver should preclude any argument for an implied leave to present evidence.

Whether the compromise agreement (or novation) cleanly extinguished the original trust relationship and, by extension, Tan’s criminal liability for estafa.
Whether an ordinary creditor-debtor situation resulting from such a compromise can serve as a valid defense to the criminal charge of estafa.