G.R. No. L-41176 - Echaus vs. Court of Appeals

Rodolfo Echaus was charged with estafa in Criminal Case No. 71522 in the Court of First Instance of Manila.
The prosecution alleged that Echaus, posing as an authorized purchasing agent for the Sea Breeze Hotel, defrauded Philrem Electrical and Auto Supply, Inc. by obtaining electrical items worth P6,760 through false representations.
Echaus issued two postdated checks (Exhibits "C" and "D") to pay for the items, knowing he did not have sufficient funds to cover them when they fell due.

Miguel Bicharra, the sales manager of Philrem, testified that Echaus misrepresented himself as the purchasing agent for the Sea Breeze Hotel.
Bicharra was convinced by Echaus's claims and accepted postdated checks as payment, despite initially requesting cash.
The checks were dishonored upon presentation at the bank, leading to a demand letter being sent to the Sea Breeze Hotel, which denied Echaus's authority to make purchases on its behalf.

The trial court found Echaus guilty of estafa, sentencing him to an indeterminate penalty and ordering him to indemnify Philrem for the amount of the checks.
The Court of Appeals affirmed the trial court's decision, emphasizing that Echaus's actions constituted deceit as defined under Article 315 of the Revised Penal Code.

Echaus contended that the appellate court erred in finding him guilty of estafa, arguing that the prosecution's evidence of misrepresentation was hearsay.
He claimed that Bicharra was aware of his insufficient funds and that he had informed Bicharra that money would be forthcoming from the hotel, thus negating any intent to defraud.

The appellate court acknowledged the hearsay nature of the letter from the Sea Breeze Hotel but maintained that the essential elements of deceit were established through Bicharra's testimony.
The court noted that Echaus's representations led Bicharra to believe he was authorized to purchase on behalf of the hotel, resulting in Philrem suff...continue reading