Title
People vs Bedoya
Case
G.R. No. 5100
Decision Date
Nov 3, 1909
Emilio Bedoya is acquitted of estafa as the Supreme Court finds that the delivery of a bill of exchange fulfilled the original obligation, discharging all liabilities.
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Case Digest (G.R. No. 5100)

Facts:

  • Emilio Bedoya was the defendant, and the United States was the plaintiff.
  • On May 18, 1908, Bedoya received goods valued at P1,312.40 from The Schweiger Import and Export Company on a commission basis.
  • He was required to account for the goods within thirty days but failed to return them or make payment.
  • Allegations of estafa (fraud) were made against Bedoya.
  • Evidence included testimonies from Guamis & Co. and Sprungli & Co., indicating Bedoya misrepresented his intentions.
  • Guamis & Co. found Bedoya selling undershirts at a lower price through a third party, while Sprungli & Co. discovered he had not opened a store as claimed.
  • An invoice and a bill of exchange were presented as evidence of Bedoya's obligation.
  • Bedoya admitted to receiving the goods but claimed they were on credit, not commission.
  • The trial court convicted him, sentencing him to two years and three months of imprisonment, ordering restitution, and imposing costs.
  • Bedoya appealed the decision.

Issue:

  • (Unlock)

Ruling:

  • The court ruled that the contract was a commission agreement, supported by Bedoya's written admission.
  • Bedoya did not fulfill his obligation to pay for the goods, as the draft he provided was not honored, thus upholding the charge of estafa...(Unlock)

Ratio:

  • The court's decision focused on the interpretation of the contract between Bedoya and The Schweiger Import and Export Company.
  • Bedoya's acknowledgment of receiving the goods on a commission basis established his obligation to return unsold goods or pay for those sold within the specified time.
  • The delivery of a draft as payment does not constitute actual payment unless c...continue reading

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