G.R. No. 156558; June 14, 2004
George Vincoy, petitioner, vs. Hon. Court of Appeals and People of the Philippines, respondents.

FACTS

Petitioner George Vincoy was charged with estafa under Article 315, paragraph 2(a) of the Revised Penal Code. The prosecution established that business partners Rolando Flores and Lizah Cimafranca engaged Vincoy to provide thirty dump trucks and two payloaders for a hauling project. Vincoy required a mobilization fund of ₱600,000. Complainants paid an initial ₱200,000 in cash. For the ₱400,000 balance, Flores obtained a manager’s check from Banco de Oro. On March 14, 1996, the check was encashed, and the proceeds were handed to Vincoy, who issued a receipt for the full ₱600,000. Only one dump truck was delivered. After demands for a refund, Vincoy gave complainants a check for ₱715,000 from a third party, requesting the return of his original receipt. This replacement check was dishonored.
Vincoy denied criminal liability, claiming he never received the ₱400,000 because the manager’s check was not in his name. He asserted he issued the receipt for ₱600,000 to include a supposed commission and that the transaction was cancelled when he discovered the check’s payee. The trial court found his version incredible.

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for estafa, despite his claim that the prosecution failed to prove his receipt of the money and criminal deceit beyond reasonable doubt.

RULING

The Supreme Court denied the petition and affirmed the conviction. The factual findings of the trial court, as affirmed by the Court of Appeals, that Vincoy received the ₱600,000 mobilization fund, are conclusive. The Court emphasized that factual determinations of lower courts, especially when affirming the credibility of prosecution witnesses, are accorded great weight and respect. Vincoy’s denial cannot prevail over the positive and consistent testimonies of the complainants detailing the payment and subsequent fraudulent failure to deliver the equipment.
The legal logic centers on the elements of estafa by deceit. The prosecution successfully proved that Vincoy made a false pretense—that he could mobilize the required equipment—which induced complainants to part with their money. His subsequent misappropriation was evident from his failure to deliver the trucks and his issuance of a worthless check upon demand for restitution. The Court clarified that the prosecution’s case rested on the deceit in obtaining the money, not on the dishonored check itself, which was merely corroborative evidence of his fraudulent intent and failure to return the funds. Thus, all elements of estafa under Article 315(2)(a) were established beyond reasonable doubt.