Facts:

The case involves Agustin Fernandez as the defendant and the United States as the plaintiff. The events leading to the case began in March 1904 when the municipality of Iloilo passed a resolution to clean latrines or water-closets in the city. To fund this service, the municipality levied a tax that varied based on classifications of property owners. In April 1904, the municipality decided to lease the latrine cleaning service to the lowest bidder, which was awarded to Fernandez for the year 1904. Following this, Fernandez was granted extensions for the contracts in 1905 and 1906, with adjustments in the rates he charged for the cleaning services.

However, in June 1906, the provincial board declared the tax collected by the municipality as illegal and null, leading to the suspension of Fernandez's contract. The municipality had categorized latrines into three classes, with different rates for each class. Property owners were required to pay for the service within a spe...

Facts:

1. Background of the Case:

   • In March 1904, the municipality of Iloilo passed a resolution to clean latrines or water-closets in the city. A tax was levied for this service, with rates varying based on classifications.
   • In April 1904, the municipality decided to lease the latrine cleaning service to the lowest bidder. Agustin Fernandez, the defendant, was awarded the contract for 1904, 1905, and 1906, with varying rebates in rates.
   • The service was divided into three classes: first class (P6 per quarter), second class (P3 per quarter), and third class (P1.50 per quarter).

2. Contractual Arrangements:

   • Fernandez was entitled to collect P1.20 per month for latrines in the zone built of strong materials and P0.40 for those in the zone of light materials in 1905.
   • In 1906, the rates were modified to P0.60 for first class, P0.50 for second class, and P0.40 for third class latrines per month.
   • The municipality collected taxes from property owners, but there was no ordinance compelling property owners to accept the services of the municipal contractor.

3. Voluntary Nature of Payments:

   • Property owners voluntarily paid for the service, and those who failed to pay were removed from the contractor’s list.
   • Private enterprises also offered latrine cleaning services in Iloilo, and there was no prohibition against competition with the municipal contractor.

4. Allegations Against Fernandez:

   • Fernandez collected payments from property owners whose names did not appear on the official municipal list.
   • The prosecution alleged that Fernandez committed estafa (fraud) by collecting payments for services not covered by the municipal contract.

5. Evidence Presented:

   • Witnesses testified that private enterprises existed in Iloilo for latrine cleaning, and Fernandez performed work for property owners outside the municipal contract.
   • There was no evidence of deceit or fraud in Fernandez’s collections, as he was entitled to compensation for services rendered.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Voluntary Nature of Payments:

   • Property owners voluntarily paid for the latrine cleaning services, and there was no compulsion to accept the municipal contractor’s services.
   • Fernandez’s collections were not made on behalf of the municipality but as compensation for services rendered.

2. Absence of Deceit or Fraud:

   • To sustain a charge of estafa, there must be deceit or fraud. The Court found no evidence that Fernandez acted with deceit or malice in collecting payments.
   • Fernandez performed the work and was entitled to collect the agreed-upon compensation.

3. No Damage or Prejudice:

   • The municipality had no right to collect payments for services rendered by Fernandez outside the municipal contract.
   • Fernandez’s actions did not damage or prejudice the municipality or the property owners.

4. Legal Doctrine:

   • The Court reiterated the doctrine that estafa requires proof of deceit or fraud, which was not established in this case.

Conclusion:

The Supreme Court acquitted Agustin Fernandez, ruling that his actions did not constitute estafa. The decision emphasized the voluntary nature of the payments and the absence of deceit or fraud in Fernandez’s collections.