Case Summary (G.R. No. 148730)
Factual Background
Vicente was charged with estafa under Article 315(1)(b) of the Revised Penal Code (RPC), based on an information filed on September 10, 2010. The charge stemmed from events around June 2008 when Vicente allegedly received in trust an amount of P42,600.00 from Roxaco, intended as payment for services by Winner through its account officer, Bethea Liwanag. Instead of fulfilling this obligation, Vicente misappropriated the funds.
Arraignment and Pre-Trial Developments
Vicente was arraigned on April 24, 2012, pleading not guilty. During a pre-trial conference, essential facts were admitted, including Vicente’s identity and prior dealings with Roxaco. A dispute arose regarding the contract terms between Vicente, Roxaco, and Winner, leading to conflicting testimonies about the obligations arising from these relationships.
Prosecution's Case
Liwanag testified on behalf of the prosecution, detailing her interactions with Vicente regarding a contract for billboard services with Roxaco. The prosecution established that Vicente’s actions resulted in Roxaco paying him, while Winner had not been compensated for their work, despite sending a demand for payment.
Defense Presentation
Vicente contended that his contract with Roxaco was exclusive and that he merely subcontracted services to Winner. He argued that the financial arrangements between him and Winner did not constitute a trust, thus negating the elements of estafa. Vicente maintained that any funds received were rightfully his under the terms agreed with Roxaco.
Regional Trial Court Ruling
On May 17, 2016, the RTC convicted Vicente of estafa, imposing a sentence of thirteen years of reclusion temporal, alongside requiring him to pay damages to Winner. The court found that all elements of estafa were satisfied, noting Vicente's admitted obligation to pay Winner and his failure to do so despite demand.
Court of Appeals Decision
The Court of Appeals, in its October 30, 2018 decision, affirmed Vicente’s conviction but modified the penalty to six months of arresto mayor, referencing the applicability of Republic Act No. 10951, which adjusted penalties based on the amount involved.
Arguments on Appeal
Vicente appealed, arguing that the prosecution failed to prove two critical elements of estafa: (1) that he received money in trust, and (2) that he misappropriated it. He maintained that his obligation to pay Winner was separate and distinct from his contract with Roxaco.
Respondent's Position
The People argued that the prosecution demonstrated beyond reasonable
...continue readingCase Syllabus (G.R. No. 148730)
Case Background
- The case involves a Petition for Review on Certiorari filed by Rodolfo "Sonny" D. Vicente, challenging the Decision dated October 30, 2018, and the Resolution dated April 3, 2019, of the Court of Appeals (CA) in CA-G.R. CR No. 38867.
- The CA had affirmed the Judgment dated May 17, 2016, of the Regional Trial Court (RTC) of Caloocan City, Branch 122, which convicted Vicente of estafa under Article 315(1)(b) of the Revised Penal Code (RPC).
- The RTC sentenced Vicente to thirteen years of reclusion temporal but the CA modified the penalty to six months of arresto mayor.
Antecedents
- Vicente was charged with estafa in an Information dated September 10, 2010, which alleged he received P42,600.00 in trust from Roxaco Land Corporation to pay Winner Sign Graphics but misappropriated the amount.
- Vicente pleaded not guilty during arraignment on April 24, 2012.
- The pre-trial conference confirmed the RTC's jurisdiction and admitted key facts including Vicente's identity and a check issued to him by Roxaco.
Testimonies and Evidence
- Liwanag's Testimony: Bethea Liwanag, an account officer of Winner, testified regarding Vicente's inquiries about billboard services, the contractual arrangement between Winner and Roxaco, and subsequent payment issues.
- Vicente informed Liwanag that Gamboa would act as Roxaco's representative, which led t