Case Digest (G.R. No. L-5840) Core Legal Reasoning Model
Facts:
In the case The United States vs. Eusebio Clarin (17 Phil. 84, G.R. No. 5840, September 17, 1910), Pedro Larin entrusted Pedro Tarug with P172 to be used in a business venture of buying and selling mangoes, where Tarug was accompanied by Eusebio Clarin and Carlos de Guzman. They agreed to equally divide the profits generated from the business among the four parties. The mango trading proceeded, yielding P203 in revenue; however, Tarug, Clarin, and Guzman failed to deliver Larin his rightful share of the profits nor did they provide an account of the invested capital. Larin filed a criminal complaint charging estafa against the trio, but the provincial fiscal only filed an information against Clarin, accusing him of unlawfully appropriating the original P172 capital and Larin’s P15.50 share of the profits. Tarug and Guzman testified assuming their participation alongside Clarin. The Court of First Instance of Pampanga convicted Clarin, sentencing him to six months' arresto m
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Case Digest (G.R. No. L-5840) Expanded Legal Reasoning Model
Facts:
- Background and Agreement
- Pedro Larin delivered P172 to Pedro Tarug with the intention that Tarug, together with Eusebio Clarin and Carlos de Guzman, would engage in the buying and selling of mangoes.
- Larin and the three men entered into an agreement to equally divide the profits in the business.
- Conduct of Transaction
- Tarug, Clarin, and Guzman traded mangoes and earned a total of P203 as profits.
- Despite the agreement, they did not deliver Larin his share of the profits nor did they provide an accounting of the capital.
- Legal Action
- Pedro Larin filed a charge of estafa (swindling) against the parties involved.
- The provincial fiscal only filed information against Eusebio Clarin, accusing him of appropriating both the P172 capital and Larin’s share of profits amounting to P15.50.
- Pedro Tarug and Carlos de Guzman appeared as witnesses and implied they were also involved.
- Trial Court Decision
- The Court of First Instance of Pampanga convicted Eusebio Clarin and sentenced him to six months' arresto mayor with accessory penalties.
- Clarin was ordered to return P172 to Larin plus P30.50 as Larin’s share of the profits, with subsidiary imprisonment as penalty for insolvency.
- Clarin was also ordered to pay costs.
- Appeal
- Clarin appealed the decision, raising the issue of the nature of the transaction and his liability.
Issues:
- Whether the money delivered by Larin to Tarug, Clarin, and Guzman constituted a partnership investment or a deposit that would render the parties liable for estafa in case of non-return.
- Whether the refusal or failure to return the capital and share of profits constitutes estafa under Philippine criminal law.
- Whether Eusebio Clarin was criminally liable for estafa for the appropriation of the capital and profits.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)