G.R. No. 179814, December 7, 2015
WILFRED N. CHIOK, Petitioner, vs. PEOPLE OF THE PHILIPPINES and RUFINA CHUA, Respondents.

FACTS

Petitioner Wilfred N. Chiok was charged with estafa under Article 315, paragraph 1(b) of the Revised Penal Code. The Information alleged that in June 1995, in San Juan, Metro Manila, Chiok received from Rufina Chua the amount of ₱9,563,900.00 in trust to buy shares of stock, under the obligation to deliver the documents or return the amount if the purchase did not materialize. Instead, he misappropriated and converted the money to his own use, and despite demands, failed to return or account for it.
The prosecution’s evidence showed that Chua met Chiok in mid-1989, and he offered to be her investment adviser. She made an initial investment, which was rolled over with profits until 1994. In mid-1995, she accepted his proposal to buy shares in bulk. She deposited ₱7,100,000.00 to Chiok’s bank account and delivered ₱2,463,900.00 in cash to him at a restaurant. Chiok later gave her two interbank checks to reassure her, but both were dishonored. Chiok, in his defense, denied enticing Chua to invest. He claimed the money was her investment in an unregistered partnership they formed, and that he invested ₱8,000,000.00 of it with a businesswoman, Yu Que Ngo.
The Regional Trial Court (RTC) convicted Chiok of estafa. It sentenced him to imprisonment and ordered him to pay Chua ₱9,563,900.00 with legal interest. The RTC also cancelled his bail. Chiok appealed. The Court of Appeals (CA) reversed the RTC’s decision and acquitted Chiok for failure of the prosecution to prove his guilt beyond reasonable doubt. However, the CA ordered Chiok to pay Chua the principal amount of ₱9,500,000.00, plus legal interest.

ISSUE

Whether the Court of Appeals erred in acquitting Chiok of estafa but still ordering him to pay civil liability to Rufina Chua.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that an acquittal based on reasonable doubt does not preclude a finding of civil liability, as the civil action is independent of the criminal case when the acquittal is based on lack of proof beyond reasonable doubt, not on a finding that the accused did not commit the act. The civil liability may be based on quasi-delict or contract. In this case, the CA correctly found that while the prosecution failed to prove criminal intent for estafa beyond reasonable doubt, the evidence established Chiok’s civil obligation to return the money received from Chua. The Court also upheld the award of interest, noting that the legal interest rate of 6% per annum from the time of judicial demand (filing of the case) was proper, and this rate would increase to 12% per annum from the finality of judgment until full payment.