Case Summary (G.R. No. 174113)
Facts and Proceedings
Cheng was charged with three counts of Estafa under Article 315 (1) (b) of the Revised Penal Code (RPC). The prosecution alleged that Rodriguez entrusted various pieces of jewelry to Cheng to sell on a commission basis, with specific agreements stipulating the obligation to either remit proceeds to Rodriguez or return unsold items. After several jewelry deliveries during 1997, Cheng issued a check as security but failed to return the items or remit the proceeds. The check was ultimately dishonored for insufficient funds and because the account was closed. In her defense, Cheng denied receiving the jewelry and claimed that the agreements were related to a loan, asserting that the transactions did not constitute a commission-based sale.
RTC Ruling
On December 7, 2000, the Regional Trial Court (RTC) found Cheng guilty of three counts of Estafa and imposed varying indeterminate sentences, which ranged from four years and two months to twenty years of reclusion temporal, depending on the amount involved in each count. The RTC determined that the prosecution successfully established Cheng's guilt beyond reasonable doubt based on the evidentiary support from Rodriguez's testimony and corresponding documentation.
CA Ruling
The Court of Appeals (CA) affirmed Cheng’s conviction on March 28, 2006, with modifications to the penalties. It emphasized the credibility of Rodriguez's testimony compared to Cheng’s uncorroborated claims. The CA found that the evidence presented demonstrated Cheng's guilt as it met the elements required for Estafa under the RPC and modified the penalties to align with jurisprudence.
Core Issue
The primary issue was whether the CA properly affirmed Cheng's conviction for Estafa as defined and penalized under Article 315 (1) (b) of the RPC.
Court's Ruling
The Supreme Court upheld the decisions of both the RTC and CA, determining that the prosecution sufficiently established the elements of Estafa. The Court reiterated that the nature of the transaction was indeed a commission-based agreement, not a simple sale, thereby establishing Cheng's obligation to either remit the proceeds or return the jewelry. The dishonor of the checks issued by Cheng was interpreted as in
...continue readingCase Syllabus (G.R. No. 174113)
Case Overview
- This case involves Paz Cheng y Chu (the Petitioner) challenging her conviction for three counts of Estafa (swindling) as defined under Article 315 (1) (b) of the Revised Penal Code (RPC).
- The case was brought before the Supreme Court following the affirmation of her conviction by the Court of Appeals (CA) in CA-G.R. CR No. 24871.
Facts of the Case
- Private complainant Rowena Rodriguez and Cheng entered into an agreement where Rodriguez would deliver jewelry to Cheng for sale on a commission basis.
- Cheng was obligated to remit proceeds from sales or return unsold jewelry within one month.
- Rodriguez delivered jewelry on three separate occasions, with values of P18,000.00, P36,000.00, and P257,950.00, respectively.
- Cheng issued a check for P120,000.00 as partial security for the jewelry but failed to remit proceeds or return unsold items.
- The check was dishonored twice due to insufficient funds and a closed account.
- Rodriguez confronted Cheng, resulting in Cheng's remark that indicated intent not to pay, prompting Rodriguez to file criminal charges.
RTC Ruling
- The Regional Trial Court (RTC) found Cheng guilty beyond reasonable doubt of three counts of Estafa.
- Cheng received varying indeterminate sentences for each count, with specifics on the d