Case Summary (G.R. No. 146735)
Facts of the Case
The case arose from a complaint filed by Emmanuel Ang Jaranilla, who engaged in money-changing transactions with Delgado. On July 9, 1993, Delgado approached Jaranilla with a proposal to exchange USD 74,000 for Philippine pesos. After consultation with his father, Manuel Ang, Jaranilla agreed to the deal. He issued a Metrobank check amounting to PhP 2,029,820 to be exchanged at a specified rate. The check was endorsed by Jaranilla’s secretary, Fely Aquino, who met with Delgado at a Metrobank branch to encash the check. Upon receiving the funds, Delgado stated that she needed to retrieve the dollars from her vehicle but subsequently absconded. Jaranilla made repeated attempts to contact her, but she failed to meet her obligation, leading him to file a criminal complaint for estafa.
Rulings of the Trial Court
The Regional Trial Court (RTC) found Delgado guilty of estafa based on the evidence presented, concluding that she defrauded Jaranilla by means of false representations. The RTC sentenced her to twenty years of reclusion temporal and required her to repay Jaranilla the amount of PhP 2,029,820, with annual compounded interest. The RTC emphasized the credibility of the prosecution's witnesses over that of Delgado's defense.
Court of Appeals Decision
Delgado and Jaranilla both appealed the RTC’s decision to the Court of Appeals (CA). The CA upheld Delgado's conviction while modifying the penalty to allow for an indeterminate sentence, ranging from 4 years and 2 months of prision correccional to 20 years of reclusion temporal. It also ordered the payment of moral and exemplary damages and attorney's fees to Jaranilla. The CA ruled that interest on the amount should accrue from the date Delgado absconded with the money, July 9, 1993.
Assignment of Errors by Delgado
In her petition, Delgado raised several arguments claiming that the RTC and CA erred in their findings. Specifically, she contended that Jaranilla was not the proper complainant as the funds originated from Manuel Ang. She argued that she was capable of holding the USD 74,000 based on her previous business transactions and that her witness, Alabado, was more credible than Aquino.
Court's Ruling on the Errors
The Supreme Court dismissed Delgado's petition, reaffirming the findings of both the RTC and CA. It ruled that the identity of the complainant was immaterial, as the transaction was between Jaranilla and Delgado, and that the failure to deliver the promised dollars was a clear indicator of deceit. The Cou
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Case Overview
- The case revolves around a Petition for Review on Certiorari filed by Adela B. Delgado contesting a decision by the Court of Appeals (CA) affirming her conviction for estafa by the Regional Trial Court (RTC).
- The case citation is G.R. No. 161178, decided on February 5, 2010.
Facts of the Case
- The case originated from a complaint filed by Emmanuel Ang Jaranilla, who accused Delgado of estafa based on fraudulent representations.
- On July 9, 1993, Delgado falsely claimed to possess USD 74,000 and sought to exchange it for Philippine pesos at a rate of PhP 27.43 to the dollar.
- After consultation with his father, Jaranilla agreed to the exchange and issued a check for PhP 2,029,820, which was entrusted to his secretary, Fely Aquino.
- Delgado met Aquino at the Metrobank branch in Binondo, where they both endorsed the check. After receiving the cash, Delgado claimed to retrieve the dollars from her car but absconded instead.
- Despite repeated demands from Jaranilla for the dollars, Delgado failed to deliver, prompting Jaranilla to file a complaint.
Trial Court Proceedings
- The RTC found the prosecution's evidence credible and convicted Delgado of estafa under Article 315 of the Revised Penal Code.
- The RTC sentenced Delgado to