Case Summary (G.R. No. 208113)
Factual Background
On March 11, 1999, an Information for estafa was lodged against petitioner Diaz in the Regional Trial Court of Manila. The prosecution's case rested on the testimony of respondent Arcilla, who claimed that merchandise worth P35,300.00 was entrusted to petitioner on February 20, 1996, with expectations to remit sales proceeds or return unsold items within a specified period. The petitioner only remitted P3,300.00 and allegedly failed to fulfill her obligations despite repeated demands from the respondent. In her defense, the petitioner argued that she did not act as an agent and had only engaged in previous transactions involving gift checks and purchase order cards, asserting that she did not receive the merchandise as claimed.
Trial Court Ruling
The Regional Trial Court acquitted the petitioner of estafa charges but found her civilly liable to pay the respondent P32,000.00, acknowledging that while prosecution failed to establish intent to defraud, the petitioner had admitted to receiving gift checks totaling that amount. The RTC regarded the relationship between the parties as akin to a principal-agent dynamic, which imposes civil liability on the agent for damages resulting from non-performance of duties.
Court of Appeals Ruling
On appeal, the Court of Appeals upheld the civil liability of the petitioner. It ruled that the acknowledgment receipt dated February 20, 1996, substantiated the transaction between the parties and the petitioner's subsequent failure to remit or return the goods. The appellate court rejected the petitioner's claims about signing blank documents and modified the interest award to commence from the time of extrajudicial demand on July 28, 1998, applying a 6% per annum interest rate as opposed to the 12% initially favored by the RTC. A motion for reconsideration filed by the petitioner was denied.
Legal Issue Presented
The central issue that arose before the Supreme Court was whether the Court of Appeals erred in affirming the finding of civil liability against petitioner Diaz.
Supreme Court's Ruling
The Supreme Court determined that the petition lacked merit and clarified that the cessation of a criminal action does not extinguish civil liability when an acquittal emerges from a reasonable doubt. It affirmed the appellate court's reliance on the preponderance of evidence standard, stating that the acknowledgment receipt effectively demonstrated the
...continue readingCase Syllabus (G.R. No. 208113)
Background of the Case
- The case involves a petition for review on certiorari filed by Dolores Diaz (petitioner) against the Decision dated January 30, 2013, and the Resolution dated July 10, 2013, of the Court of Appeals (CA) in CA-G.R. CV No. 97571.
- The CA decision directed the petitioner to pay respondent Leticia S. Arcilla (respondent) P32,000.00, with legal interest at 6% per annum from July 28, 1998, until the decision becomes final, and thereafter at 12% per annum on the outstanding balance until full satisfaction.
Facts of the Case
- On March 11, 1999, an Information for estafa was filed against the petitioner in the Regional Trial Court of Manila, Branch 5.
- The prosecution's case was based on the testimony of the respondent, who claimed to be a businesswoman selling goods through agents, including the petitioner, under conditions that the proceeds be returned or unsold items returned after a month.
- The respondent alleged that on February 20, 1996, she entrusted merchandise worth P35,300.00 to the petitioner, evidenced by an acknowledgment receipt signed by the latter.
- The petitioner only remitted P3,300.00 by March 20, 1996, and subsequently failed to remit further or return the goods despite the respondent's demands.
- In her defense, the petitioner admitted previous dealings with the respondent but denied being an agent, claiming she merely purchased items on an installment basis and did not receive P32,000.00 worth of merchandise.