Case Summary (G.R. No. 204755)
Criminal Charges and Evidence
The charges against Tria stem from events occurring on March 8, 2000, when she received jewelry from Seven Sphere Enterprises under a consignment agreement. Tria was obligated to remit the proceeds from sales or return any unsold items within six days. Evidence presented, including Meneses’s testimony and documentation, indicated that Tria returned only eight out of the twenty-two pieces consigned to her, leaving an outstanding balance of P23,375.50. Tria issued several post-dated checks to cover this balance, but they were dishonored due to the account being closed. After failing to remit the due amount or return the remaining jewelry despite demands, Tria was charged with estafa.
Ruling of the RTC
On July 16, 2010, the RTC convicted Tria of estafa under Article 315(1)(b) of the Revised Penal Code (RPC), concluding that she had misappropriated the proceeds from the consigned items. The RTC imposed an indeterminate sentence of four years and two months to eight years of imprisonment and ordered Tria to indemnify Seven Sphere Enterprises for the unreturned amount. The Court reasoned that the essential elements of estafa were satisfied, as Tria failed to return the items or remit proceeds despite receiving clear demands.
Ruling of the Court of Appeals
The CA affirmed the RTC's decision on April 20, 2012, asserting that Tria’s guilt was established beyond a reasonable doubt. The CA dismissed Tria’s appeal for lack of merit and upheld the conviction, prompting Tria to seek reconsideration, which was denied.
Arguments by the Petitioner
In her appeal, Tria contended that the element of fraud was absent, as she returned some jewelry and had made partial payments. She argued that her actions demonstrated an absence of intent to defraud and cited an alleged agreement with Seven Sphere that allowed her to settle her balance by rendering services. Tria questioned the imposed penalty, arguing that the amount involved should not influence the calculation of her sentence due to its classification as a modifying circumstance.
Response of the Respondent
The Office of the Solicitor General contended that the appeal lacked merit and petitioned for the affirmation of Tria's conviction. They argued that the prosecution had proven all elements of estafa beyond reasonable doubt. In a subsequent filing, Tria reiterated her claims about the arrangement she had with Seven Sphere regarding her outstanding accountabilities.
Court's Findings
The Supreme Court ultimately found no merit in Tria’s appeal. It emphasized that the RTC's factual findings, which were affirmed by the CA, were binding unless exceptional circumstances arose. The Court highlighted the established elements of estafa, including the misappropriation of property received under an obligation to return or account for it. The Supreme Court also focused on the absence of any credible evidence from Tria to refute the claims against her, asserting that her explanation regarding the selling of jewelry on credit contravened the terms of the consignment agreement.
Sentencing Considerations
The Supreme Court determined that while Tria was culpable of estafa, it found grounds to modi
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Case Background
- This case concerns an appeal from the Decision dated April 20, 2012, and Resolution dated September 18, 2012, of the Court of Appeals (CA), which upheld the Regional Trial Court (RTC) ruling.
- Soledad Tria (petitioner) was found guilty beyond reasonable doubt of estafa under Article 315 (1)(b) of the Revised Penal Code.
- The RTC sentenced her to an indeterminate penalty of four (4) years and two (2) months of prision correccional as minimum, to eight (8) years of prision mayor as maximum.
Facts of the Case
- The petitioner received assorted jewelry valued at P23,375.50 from Seven Sphere Enterprises, with the obligation to sell and remit the proceeds or return unsold items within six days.
- The petitioner returned eight pieces valued at P16,380.00, leaving an unpaid balance of P31,060.00.
- She issued four post-dated checks to cover the balance, which were subsequently dishonored due to the account being closed.
- Following dishonor of the checks, the petitioner returned three pieces of jewelry, leaving an unpaid balance of P23,375.50.
- A demand letter was sent to the petitioner, but she failed to pay the outstanding amount despite receiving the letter.
Ruling of the RTC
- The RTC found the petitioner guilty of estafa, concluding that the elements of the crime were established beyond a reasonable doubt.
- The court determined that the unremitted balance was P23,370.00, after taking into accoun