Title
Delgado vs. People
Case
G.R. No. 161178
Decision Date
Feb 5, 2010
Adela Delgado convicted of estafa for defrauding Emmanuel Ang Jaranilla of PhP 2M after failing to deliver USD 74,000 post-check encashment. SC affirmed CA's ruling.
estafa
false manifestations
fraudulent representations

Case Summary (G.R. No. 161178)

Factual Background

The records showed that private respondent Jaranilla was engaged in the money changing business and had prior transactions with Delgado. On July 9, 1993, Delgado proposed exchanging USD 74,000 with Jaranilla for Philippine pesos at a specified rate of PhP 27.43 per dollar. Jaranilla agreed after consulting with his father, Manuel Ang.

To effect the exchange, Manuel Ang drew a Metrobank Check No. 061224813 payable to cash in the amount of PhP 2,029,820. Jaranilla entrusted the check to his secretary Fely Aquino (also known as Lily Ang). Aquino then met with Delgado at the Binondo Metrobank branch to encash the check. Both Aquino and Delgado endorsed and signed the check. Aquino used the name Lily Ang, the name known to Metrobank. Delgado received the cash amount of PhP 2,029,820 from the bank teller.

Delgado then claimed she did not have the dollars with her and asked Aquino to wait while she retrieved the money from her car. Delgado left and did not return. Jaranilla contacted Delgado repeatedly, but she failed to deliver the promised USD 74,000, despite repeated demands, which led to the filing of a criminal complaint for estafa.

Delgado’s Defense at Trial

Delgado denied the accusation by asserting that she met Aquino only on the afternoon of July 9, 1993. She claimed that another person, Carina Alabado, delivered the subject dollars to Aquino. Aquino’s testimony, however, denied Alabado’s role. The trial court nonetheless credited the prosecution witnesses as more reliable, and it found that Delgado took the cash and absconded without delivering the dollars.

RTC Disposition

The RTC convicted Delgado beyond reasonable doubt of estafa punishable under Art. 315, involving P2,029,820. It imposed a penalty of twenty (20) years of reclusion temporal. It also ordered Delgado to pay P2,029,820 to the aggrieved party, with interest at a legal rate compounded annually until full payment. The dispositive portion reflected the trial court’s finding that the elements of the offense were established.

Appeals to the Court of Appeals

Both Jaranilla and Delgado appealed to the CA. Jaranilla sought additional monetary relief, including interest from the date of extra-judicial demand, as well as moral and exemplary damages and attorney’s fees and litigation expenses. Delgado’s appeal focused on alleged error in the trial court’s credibility assessment and in the conviction itself.

CA Ruling and Modifications

The CA affirmed the conviction but modified the penalty by applying the Indeterminate Sentence Law, setting an indeterminate range from 4 years and 2 months of prision correccional as minimum to 20 years of reclusion temporal as maximum. The CA also set the reckoning period for the interest on P2,029,820 from July 9, 1993, the date when Delgado absconded with the money.

Further, the CA awarded Jaranilla P250,000 as moral damages, P250,000 as exemplary damages, and P100,000 as attorney’s fees, plus costs of litigation. The CA thus sustained the criminal liability while adjusting the collateral civil consequences and the sentencing format.

Issues Raised in the Supreme Court

Delgado pursued a petition for review on certiorari and challenged the CA and RTC findings. Her principal assignment of errors was that the trial courts failed to recognize: first, that the injured party and the proper private complainant was Manuel Ang, not Jaranilla; second, that she was allegedly engaged in the money changing business and therefore had the capacity to possess the USD 74,000 subject of the transaction; and third, that the testimony of her witness Alabado should have been given greater credibility than that of Aquino.

The Supreme Court’s Ruling on the Alleged Proper Complainant and Damage

The Supreme Court rejected Delgado’s argument that Manuel Ang was the injured party and that the absence of damage to Jaranilla warranted acquittal. The Court characterized the claim as a novel argument but one it considered already disposed of. Delgado argued that because the source of funds was Manuel Ang and because the check was issued by him, any damage would have been suffered by Manuel Ang rather than Jaranilla.

The Court held that Delgado’s position improperly sought to distract from the proven facts. It emphasized that Manuel Ang was not the person with whom Delgado transacted; the transaction was between Delgado and private respondent Jaranilla. The Court noted that Delgado did not dispute receiving P2,029,820 as a result of that transaction. According to the Court, the origin of the funds did not determine Delgado’s criminal liability. It reiterated that ownership is not a necessary element of the crime of estafa, and that the person prejudiced or the immediate victim of the fraud need not be the owner of the goods, citing People v. Dy and subsequent cases including Salazar v. People, First Producers Holding Corporation v. Co, and Hernandez v. Court of Appeals.

The Court found that the transaction involved Delgado’s undertaking to deliver USD 74,000 in exchange for P2,029,820, and that, while Jaranilla complied by delivering the cash, Delgado failed to comply. It ruled that even if Delgado had established that the P2,029,820 did not belong to Jaranilla, that would not negate criminal liability for estafa.

The Supreme Court’s Ruling on Alleged Capacity to Possess the Dollars

The Court also dismissed Delgado’s claim that her alleged business of money changing showed that she had the capacity to possess USD 74,000. The Court pointed out that the trial court had found Delgado failed to deliver the promised dollars to Jaranilla’s secretary Aquino at the Binondo Metrobank branch after receiving P2,029,820. It added that Delgado also failed to deliver the dollars despite repeated demands.

The Court treated Delgado’s belated assertion of capacity as incapable of excusing her failure to perform. It stressed that Delgado had not delivered what she promised “till this day,” without explanation or restitution. The Court held that Delgado could not rely on past transactions to negate deceit when she could not account for her failure to deliver at the time agreed upon. The only conclusion, absent any explanation, was that she did not possess the promised dollars at the time of the transaction, so deceit attended the deal.

The Supreme Court’s Ruling on Credibility of Witnesses

Finally, the Court rejected Delgado’s attempt to have the testimony of Alabado override that of Aquino. The Court found that Delgado offered no compelling reason to prefer Alabado’s account over Aquino’s. It reinforced the appellate standard that trial courts are best positioned to weigh conflicting testimonies since they observe the witnesses’ deportment and manner of testifying.

Accordingly, the Court reiterated the rule that factual findings by the trial court, as affirmed by the CA, receive high respect, if not conclusive effect, and appellate review generally does not disturb such findings absent a justifiable reason, citing People v. Tuason and Martinez v. Court

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