Case Summary (G.R. No. 4277)
Factual Background
Rosemarie M. Lee faced charges for estafa, as she allegedly defrauded the Philippine Bank of Communications by failing to deliver proceeds from the sale of merchandise acquired under a trust receipt agreement. The trust receipt was executed on July 26, 1982, and stipulated that she would either return the merchandise or account for the sale proceeds by October 24, 1982. Despite the bank's repeated demands, Lee failed to fulfill this obligation.
Legal Proceedings
Lee moved to quash the information against her on the basis that the allegations did not constitute an offense. She argued that violations of a trust receipt do not warrant estafa charges, claiming P.D. 115 as unconstitutional. The trial court denied her motion both on August 21, 1987, and again on October 12, 1987, affirming the validity of P.D. 115.
Issue at Hand
The central issue of this case is whether a violation of a trust receipt agreement constitutes the crime of estafa. The court ruled affirmatively, relying on the explicit provisions under P.D. 115, which categorically asserts that failing to either return goods or remit sale proceeds constitutes estafa under the Revised Penal Code.
Administrative Provisions of P.D. 115
Section 13 of P.D. 115 outlines that any failure by an entrustee to account for the proceeds or return the goods amounts to estafa, highlighting that if a corporation commits such violations, the penalties will be enforced against responsible individuals within the entity. This provision reinforces the existing legal framework that regards misappropriation of trust receipt goods as criminal.
Case Law Consideration
Petitioner’s reliance on past rulings, specifically People v. Cuevo and Sia v. People, was examined. In Cuevo, a majority opinion established that violations of trust receipts could invoke estafa charges, notwithstanding the dissenting views that arrived before the enactment of P.D. 115. The majority opinion from Cuevo clearly stated that entitlements arising from trust receipts fall under Article 315(1)(b) of the Revised Penal Code, establishing a precedent that applies to the present case.
Constitutional Challenge
Lee challenged the constitutionality of Section 13 of P.D. 115, arguing it violates the prohibition against imprisonment for non-payment of debts. However, the court clarified that the liability arises from the criminal nature of the violation against the trust receipt agreement rather than from a mere failure to pay a debt. The relationship established through the trust receipt creates obligations that fall outside the scope of the constitutional prohibition.
Interpretation of Trust Receipt Transactions
The court elaborated on the nature of trust receipt transactions, emphasizing its dual character as both a loan and a security agreement. The g
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Case Citation
- G.R. No. 80544
- Date: July 05, 1989
- Division: Third Division
- Ponente: Justice Gutierrez, Jr.
Background of the Case
- Petitioner Rosemarie M. Lee was charged with estafa in relation to a trust receipt agreement.
- The accusation stemmed from her alleged failure to turn over the proceeds from the sale of merchandise covered by a trust receipt to the Philippine Bank of Communications.
- The trust receipt, dated July 26, 1982, outlined her obligations regarding the merchandise, which was valued at P154,711.97.
Allegations in the Information
- The information charged that on July 26, 1982, in Manila, Lee unlawfully defrauded the bank by:
- Not delivering the proceeds from the sale of the goods.
- Misappropriating and converting the goods for her personal use.
- The trust receipt obligated Lee to either sell the goods and remit the proceeds or return the unsold goods by October 24, 1982.
Procedural History
- Lee filed a motion to quash the information, arguing that the facts did not constitute estafa and that the Trust Receipts Law (P.D. 115) was unconstitutional.
- The trial court denied the motion, upholding the constitutionality of P.D. 115.
- Subsequent motions for reconsideration were also denied.
Legal Issue
- The central issue was whether a violation of a trust receipt agreement constitutes the crime of estafa.
Court's Ruling
- The Supreme Court affirmed that the violation of a trust