Case Summary (G.R. No. 180046)
Antecedents
In November 1995, Mary Ann Manuel introduced Eduardo Dela Vega to Victoria Collado, leading to Dela Vega investing in Collado's stock business under the promise of a monthly interest rate of 7.225%. Eduardo's initial investment amounted to P100,000, followed by additional cash deposits, leading to a total investment of approximately P5,000,000 and US$82,000. Despite these investments, Dela Vega did not receive the promised stock certificates, prompting demands for repayment that were met with dishonored checks. Consequently, Eduardo filed a criminal complaint against Victoria for estafa, asserting she misappropriated funds entrusted to her.
Lower Court Findings
On March 26, 2009, the Regional Trial Court acquitted Victoria based on reasonable doubt, concluding that the evidence presented by the prosecution lacked sufficient support to establish her guilt or civil liability. The court highlighted a lack of reliable proof that Victoria received money in trust for investment, noting inconsistencies in Eduardo's claims and lack of formal receipts for his transactions.
Court of Appeals Decision
Dissatisfied with the RTC's ruling, Eduardo appealed the civil aspect of the case to the Court of Appeals. On October 2, 2014, the CA reversed the RTC's decision concerning civil liability, finding Victoria liable to pay Eduardo P2,905,000. The CA based its decision on the acknowledgment of funds received by Victoria, corroborated by bank deposit slips and testimonies indicating that a business arrangement existed. It held that the RTC's ruling had insufficient justification for absolving Victoria from civil liability.
Issues Raised by Victoria
In her petition to the Supreme Court, Victoria contended that the CA improperly disregarded the RTC's findings and that the funds she received were intended as investments, thereby implying inherent risks and uncertainties, rather than guaranteed returns. She argued that the appellate court erred in its assessment of facts.
Supreme Court Ruling
The Supreme Court denied Victoria’s petition, emphasizing that it does not entertain issues centered on the appreciation of evidence, as these are factual matters beyond its jurisdiction in a petition for review on certiorari. The Court acknowledged the contradiction between the RTC's finding of no preponderant evidence and the CA's conclusion of Victoria's civil liability, stating that this warranted a re-examination of the evidence presented.
The Court established that an acquittal does not necessarily preclude civil liability, especially when
...continue readingCase Syllabus (G.R. No. 180046)
Core Issue
- The primary question before the court is whether preponderant evidence exists to hold Victoria B. Collado civilly liable despite her acquittal in a criminal case.
Antecedents
- In November 1995, Mary Ann Manuel introduced Victoria B. Collado to Eduardo M. Dela Vega.
- Eduardo invested in Victoria's stock business, expecting a monthly interest rate of 7.225%, beginning with an initial cash investment of P100,000.00.
- Victoria assured Eduardo that Mary Ann would monitor his investment and it would be documented through a stock certificate.
- Eduardo subsequently made additional investments through cash deliveries and bank deposits but never received a stock certificate.
- After failing to recover his investments, Eduardo issued demands for repayment.
- Victoria issued two checks (P340,000.00 and P400,000.00) dated October 7 and November 3, 1998, respectively, which were later dishonored.
Criminal Proceedings
- Eduardo filed a criminal complaint against Victoria for estafa (swindling) under Article 315 paragraph 1(b) of the Revised Penal Code.
- The complaint alleged that Victoria misappropriated P5,000,000.00 and US$82,000.00 entrusted to her for investment purposes.
- On March 26, 2009, the Regional Trial Court (RTC) acquitted Victoria based on reasonable doubt, citing:
- Lack of preponderant evidence to prove her civil liab