GR L 16480; (December, 1920) (Digest)
G.R. No. L-16480, December 11, 1920
THE UNITED STATES, plaintiff-appellee, vs. AGAPITO BELTRAN and PEDRO DE LEON, defendants. AGAPITO BELTRAN, appellant.
FACTS:
On May 10, 1919, Agapito Beltran borrowed P74.50 from Facundo Ilaw, owner of a chineleria. Beltran signed a receipt stating that he would work for Ilaw until the debt was paid and would pay by weekly installments. Beltran worked continuously in Ilaw’s shop from March 17, 1919, until August 30, 1919, during which he claimed to have paid P24 on account. Beltran left Ilaw’s employ due to a disagreement with Ilaw’s wife and insufficient work. For failing to fulfill the agreement, Beltran was prosecuted under Section 1 of Act No. 2098 (an Act relating to contracts of personal services and advances) in the municipal court and later, on appeal, in the Court of First Instance of Manila. He was found guilty and sentenced to two months’ imprisonment, ordered to pay Ilaw P83.65, and to pay half the costs. Beltran appealed, arguing that Act No. 2098 had been repealed by Act No. 2300 and that the evidence did not establish fraudulent intent.
ISSUE:
Whether Beltran’s conviction under Act No. 2098 was valid, considering the requirement of fraudulent intent at the time of contracting.
RULING:
The Supreme Court reversed the conviction and acquitted Beltran. The Court held that for a conviction under Act No. 2098 , it must be proven that at the time the contract was entered into, the employee had the intent to injure or defraud the employer. The statute punishes fraudulent practices, not mere breach of contract or failure to pay a debt. The element of fraud or bad faith is essential. In this case, the evidence did not establish that Beltran had fraudulent intent when he borrowed the money. On the contrary, his continuous work for several months after incurring the debt indicated good faith. His reason for leavingdisagreement with the employer’s wife and lack of workappeared credible. Thus, without proof of fraudulent intent, Beltran’s actions constituted only a civil breach of contract, not a criminal offense. The Court did not resolve the issue of whether Act No. 2098 was repealed by Act No. 2300 , as the disposition on the second assignment of error rendered it unnecessary.