G.R. No. 183805 - Capili vs. People

Petitioner Rodolfo “Sonny” D. Vicente was charged with estafa under Article 315(1)(b) of the Revised Penal Code (RPC) based on an Information dated September 10, 2010.
The Regional Trial Court (RTC) of Caloocan City, Branch 122, rendered a Judgment on May 17, 2016, convicting Vicente of estafa and sentencing him to thirteen (13) years of reclusion temporal, ordering him to pay actual damages of ₱35,400.00 and attorney’s fees of ₱10,000.00.
The Court of Appeals (CA) later affirmed the RTC’s Judgment but reduced the imprisonment penalty to six (6) months of arresto mayor, invoking Republic Act No. 10951.
Vicente elevated the case by filing a Petition for Review on Certiorari before the Supreme Court assailing both the conviction and the penalty.

In or about June 2008, Vicente entered into a transaction with Roxaco Land Corporation wherein he received payments as part of a contract for the creative design and printing of marketing materials related to billboards.
Roxaco Land Corporation issued a check in the amount of ₱89,000.00 in favor of Vicente, evidencing the exclusive contractual relation between them.
There was a delineated arrangement that Winner Sign Graphics was to receive a portion of the payment (₱35,400.00) as the contract price for the printing services, although Winner was not a party to the contract between Vicente and Roxaco.
Communication exchanges included:

A June 29, 2008 letter executed by Vicente.
An email and subsequent letter from Vicente indicating that Winner was only entitled to ₱35,400.00.
Testimony by Bethea Liwanag, Winner’s account officer, corroborating the facts that Roxaco dealt directly with Vicente and that Winner did not hold an independent contractual relationship with Roxaco.

Winner Sign Graphics claimed that Vicente misappropriated funds by failing to pay them their rightful ₱35,400.00 after receiving payment from Roxaco.
The complaint asserted that Vicente received money “in trust,” committed misappropriation, and, despite a formal demand letter dated July 14, 2008, failed to deliver the amount due.
Vicente, as his sole witness, contended that the agreement with Roxaco was exclusive and that his obligation toward Winner constituted a separate obligation not amounting to a trust or commission relationship.

The RTC found the existence of all four elements necessary to establish estafa under Article 315(1)(b):

The CA concurred with the evidence and findings of the RTC regarding the substantive elements of estafa but modified the imposed penalty pursuant to R.A. 10951.
Evidence presented included documentary proofs (letters, check issuance, and price quotations) and testimony from key witnesses such as Bethea Liwanag.

Whether the Court of Appeals erred in affirming, with modification, the conviction of Vicente for estafa by misappropriation.

Specifically, whether the requisite elements of estafa under Article 315(1)(b) were proven beyond reasonable doubt.
Whether the application of Republic Act No. 10951, which prescribes a less severe penalty for amounts not exceeding ₱40,000.00, was properly invoked.
Whether the receipt of money by Vicente was “in trust” or on commission, pursuant to the statutory elements of the crime of estafa.