View full case

GEORGE VINCOY v. CA

FACTS:

This case is a petition for review of the Decision dated December 20, 2002 of the Court of Appeals, affirming the Decision of the Regional Trial Court of Pasig, finding the petitioner guilty of estafa. The Information charges the petitioner with defrauding the private complainants of the amount of P600,000.00 through deceit and false pretenses.

According to the prosecution's evidence, the private complainants approached the petitioner for dump trucks and payloaders for their business. The petitioner represented that he could provide the needed vehicles upon payment of a P600,000.00 mobilization fund. The private complainants paid an initial P200,000.00 in cash and borrowed P400,000.00 from a bank to complete the payment. Upon encashing the check, the proceeds were handed over to the petitioner. The petitioner issued an official receipt for the amount of P600,000.00 instead of the agreed upon P400,000.00.

Despite the payment, only one dump truck was delivered, and the petitioner failed to return the money despite demands. The private complainants accepted a check from the petitioner as reimbursement, but the check was later dishonored.

The petitioner denied receiving P600,000.00 and claimed that he was only given a check for P400,000.00, which he arranged to be returned to the complainants. However, the trial court found the prosecution's version more credible and convicted the petitioner of estafa.

ISSUES:

  1. Whether the prosecution was able to prove the guilt of the petitioner beyond reasonable doubt for estafa under Art. 315, par. 2(a) of the Revised Penal Code.

RULING:

  1. The Court finds the petition meritorious. The decision of the Court of Appeals and the Regional Trial Court is hereby reversed and set aside. The Court holds that the prosecution did not establish the guilt of the petitioner beyond reasonable doubt for estafa under Art. 315, par. 2(a) of the Revised Penal Code.

PRINCIPLES:

  • In criminal cases, the prosecution bears the burden of proving the guilt of the accused beyond reasonable doubt. (People v. Baroga, G.R. No. 213290, January 15, 2020)

  • To establish the crime of estafa under Art. 315, par. 2(a) of the Revised Penal Code, the following elements must be proven: (a) that the money, goods, or other personal property was received by the accused in trust or on commission, or for administration, or under any other obligation involving the duty to make delivery of or to return the same; (b) that there was a misappropriation or conversion of such money and/or property by the accused or denial on his part of such receipt; (c) that such misappropriation or conversion or denial is to the prejudice of another; and (d) that there is a demand made by the offended party on the accused. (Ramos v. People, G.R. No. 187298, February 7, 2018)