G.R. No. L-30896 - Sia vs. People

Jose O. Sia, charged with estafa for alleged misappropriation of goods and proceeds under the trust receipt executed on behalf of MEMAP.

The People of the Philippines, acting on complaint of Continental Bank.

May 31, 1963: MEMAP applies for Letter of Credit.
June 5, 1963: Letter of Credit opened for $18,300.
July 24 – December 31, 1963: Period during which goods were delivered and allegedly misapplied.
December 1963: Continental Bank’s demands for payment.
October 22, 1964: Information for estafa filed.
April 28, 1983: Decision of the Supreme Court (En Banc).

1973 Philippine Constitution (case decided pre-1987).
Revised Penal Code, Article 315(1)(b), defining estafa by abuse of confidence or trust receipt.
Presidential Decree No. 115 (1973) regulating trust receipts and imposing penalties on offending corporate entities and responsible officers.

MEMAP, represented by Sia, applied for and secured an L/C from Continental Bank to import steel sheets.
Goods arrived in July 1963 and were delivered upon execution of a trust receipt obliging MEMAP to hold them “in trust” and remit sale proceeds to the Bank.
MEMAP failed to account for or return the goods or proceeds despite demands; a marginal deposit of ₱28,736.47 was forfeited, leaving a shortfall of ₱46,818.68.
Continental Bank filed a criminal information for estafa on October 22, 1964.

General Rule: Crimes committed by a corporation may be imputed to responsible officers, but only where law expressly imposes such liability.
Analysis: No provision in the Revised Penal Code makes a corporate officer personally criminally liable for failure to perform contractual obligations of the corporation.
Principle: Criminal liability must be clear and unambiguous; doubts resolved in favor of the accused.
Conclusion: Absent an express statutory mandate, Sia cannot be held personally guilty of estafa for acts done solely on behalf of MEMAP.

Two Interpretations:
1. Trust receipt as purely a security arrangement for a loan—breach gives rise only to civil liability.
2. Trust receipt as creating a true trust—violation constitutes estafa under Art. 315(1)(b).
Pre-PD 115 Practice: Parties intended a commercial financing transaction akin to a secured loan, not a penal provision for misuse of trust property.
Ambiguities in the trust receipt (e.g., manufacture of goods not expressly covered) and the dual nature of the transaction favored civil over criminal characteriz

Petitioner Jose O. Sia was President and General Manager of Metal Manufacturing Company of the Philippines, Inc. (MEMAP), engaged in steel office‐equipment manufacture.
MEMAP applied (May 31, 1963) for a letter of credit (L/C No. 63/109) with Continental Bank to import 150 M/T Cold Rolled Steel Sheets valued at US$18,300; the L/C was opened June 5, 1963.
The steel sheets arrived in July 1963 and were delivered to MEMAP under a trust receipt agreement; Sia executed the trust receipt obliging him to:
- Hold the goods in trust as property of Continental Bank.
- Sell the goods for the Bank’s account.
- Remit proceeds immediately upon sale to the Bank to cover the relative acceptance and any other indebtedness.
Sia deposited P28,736.47 as marginal deposit; upon default, Continental Bank applied this deposit against the P71,023.60 value of the goods, leaving a balance of P46,818.68.
Despite demands dated December 17 and 27, 1963, MEMAP (through Sia) neither returned the goods nor accounted for sale proceeds; the Fiscal filed an information for estafa on October 22, 1964.

The Court of First Instance of Manila convicted Sia of estafa under Article 315(1)(b) of the Revised Penal Code, finding misappropriation and conversion of trust‐receipt goods.
The Court of Appeals affirmed, holding that corporate officers are criminally liable for offenses committed by the corporation.
Sia elevated the case to the Supreme Court by petition for review.

May an officer who acted solely on behalf of a corporation be held personally liable for estafa when the corporation committed the alleged act?
Does violation of a trust receipt agreement constitute estafa under Article 315(1)(b) of the Revised Penal Code?
Are the provisions of Article 315 adequate to punish trust‐receipt violations, or did the promulgation of Presidential Decree No. 115 indicate a legislative intent to create a separate penal regime?

Uncontested antecedents: Sia’s corporate capacity; application and approval of the L/C; delivery under trust receipt; default on payment; demand letters; computation of u