GR 181692; (August, 2013) (Digest)
G.R. No. 181692; August 14, 2013
ADELAIDA SORIANO, PETITIONER, vs. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Adelaida Soriano was charged with estafa under Article 315(2)(a) of the Revised Penal Code. The Information alleged that on September 9, 1994, she defrauded Consolacion Alagao by misrepresenting her capacity to pay for 398 sacks of corn grits valued at ₱85,607.00. After delivery, Soriano failed to pay and instead had Alagao sign a cash voucher falsely indicating receipt of payment. During pre-trial, the parties admitted several transactions, including a ₱40,000.00 loan secured by a real estate mortgage executed by Alagao’s daughter in February 1994. It was also admitted that Alagao received a total of ₱51,730.00 from Soriano in fertilizers, seeds, and cash advances. The parties further agreed that on September 9, 1994, Alagao delivered corn worth ₱85,607.00, but disputed whether this was a new sale or a payment for prior obligations.
ISSUE
Whether the Court of Appeals erred in ordering Soriano to pay Alagao the balance for the corn delivered, despite the existence of a loan and prior deliveries that could constitute compensation or set-off.
RULING
The Supreme Court modified the CA decision, reducing the civil liability. The Court acquitted Soriano of estafa due to lack of criminal intent, as the transactions arose from a pre-existing contractual relationship, not deceit. On civil liability, the Court held that legal compensation under Article 1279 of the Civil Code could not apply automatically. For compensation to occur, the debts must be liquidated and demandable. Here, the loan contract provided that the loan of ₱40,000.00 would be repaid by giving Soriano one-fourth of every harvest from the mortgaged land. This share of harvests, not being a sum of money, was not yet liquidated as the number of harvests delivered was disputed. Therefore, the value of the corn delivered on September 9, 1994, could not be fully set off against the unliquidated harvest shares. After deducting the admitted prior cash advances and the value of a partial delivery, the Court computed the remaining balance payable by Soriano to be ₱30,877.00, plus legal interest. The ruling emphasizes that compensation requires both debts to consist in a sum of money or be liquidated and demandable, conditions absent in this case due to the nature of the loan repayment in agricultural harvests.