Facts:

The case involves Ramon L. Uy as the petitioner and the People of the Philippines as the respondent. The events leading to the case began in November 1995 when Uy allegedly defrauded Eugene Yu, the private complainant, by convincing him to invest in a low-cost housing project. Uy represented himself as a businessman and developer, claiming to be the president of Trans-Builders Resources and Development Corporation. Yu, persuaded by these representations, agreed to invest ₱3,500,000.00, with the promise that Uy would return ₱4,500,000.00 within six months, which included interest.

On October 28, 1995, an undated Investment Agreement was signed by both parties, detailing the terms of the investment. Yu issued a check for ₱3,500,000.00 to Uy, who in turn issued a post-dated check for ₱4,500,000.00. However, when Yu attempted to cash the check, it was dishonored due to insufficient funds. Subsequent inquiries revealed that Uy did not have any ongoing housing projects as he had...

Facts:

Background of the Case
Ramon L. Uy was charged with Estafa under Article 315, paragraph 2 of the Revised Penal Code for allegedly defrauding Eugene Yu of P3,500,000.00 through false representations regarding a low-cost housing project in Cagayan de Oro.

Initial Meeting and Business Proposal
In 1993, Eugene Yu met Uy during a CREBA convention. Uy presented himself as a developer of low-cost housing projects and proposed a joint venture in Parañaque City, which proceeded successfully. Later, Uy proposed another project in Cagayan de Oro.

Signing of the Investment Agreement
On 28 October 1995, Uy and Yu signed an Investment Agreement. Yu agreed to invest P3,500,000.00 for the development of a low-cost housing project, with a promised return of P4,500,000.00 after six months. Yu issued a check for P3,500,000.00, and Uy issued a post-dated check for P4,500,000.00.

Discovery of Fraud
Yu’s check was debited, but Uy’s check was dishonored due to insufficient funds. Yu discovered that Uy’s company had no ongoing low-cost housing project in Cagayan de Oro, as certified by the HLURB.

Trial Court Proceedings
Uy was arraigned and pleaded not guilty. During the trial, Yu testified about Uy’s misrepresentations, while Uy claimed the transaction was a simple loan.

RTC and CA Rulings
The RTC convicted Uy of Estafa and sentenced him to an indeterminate penalty of 10 to 20 years. The Court of Appeals affirmed the conviction but reduced the minimum sentence to 2 years and 4 months.

Issue:

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Ruling:

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Ratio:

Nature of the Agreement
The Court held that the transaction was an Investment Agreement, not a simple loan. The written agreement clearly outlined the terms of the investment and the specific purpose of the funds.

Elements of Estafa
The Court found that all elements of Estafa were present:

1. Uy made false representations about having a low-cost housing project in Cagayan de Oro.
2. Yu relied on these representations and invested P3,500,000.00.
3. Uy’s check was dishonored, and Yu suffered damage.

Due Process
Uy was not denied due process. He was arraigned, informed of the charges, and given the opportunity to defend himself.

Contract of Adhesion
The Investment Agreement was not a contract of adhesion. Although prepared by Yu’s lawyer, Uy participated in its drafting and understood its terms.

Check Date
The Court agreed with the trial court’s reasoning that the check was post-dated, and the discrepancy did not affect the validity of the agreement.

Penalty
The Court modified the penalty imposed by the RTC and CA. The maximum penalty was set at 20 years of reclusion temporal, and the minimum was reduced to within the range of the penalty next lower.

Interest on Damages
The Court reduced the interest on the awarded damages to 6% per annum from 30 May 1996, but upon finality of the decision, the interest would increase to 12% per annum.

Conclusion:

The Supreme Court upheld Uy’s conviction for Estafa, affirming the CA’s decision with modifications to the penalty and interest rate.