GR 208113; (December, 2015) (Digest)
G.R. No. 208113, December 02, 2015
DOLORES DIAZ, PETITIONER, VS. PEOPLE OF THE PHILIPPINES AND LETICIA S. ARCILLA, RESPONDENTS.
FACTS
Petitioner Dolores Diaz was charged with estafa before the Regional Trial Court (RTC) for allegedly failing to remit proceeds or return unsold merchandise valued at ₱32,000.00, which she received on consignment from respondent Leticia Arcilla. The prosecution presented an acknowledgment receipt dated February 20, 1996, signed by Diaz, evidencing the transaction. Arcilla testified that Diaz remitted only ₱3,300.00 and subsequently ignored demands for the balance or the return of the goods.
In her defense, Diaz denied the 1996 transaction, claiming her prior dealings with Arcilla involved only the purchase of gift checks and purchase order cards on installment, which she had fully settled by 1995. She alleged she was made to sign blank documents during those past transactions. The RTC acquitted Diaz of estafa due to lack of criminal intent but held her civilly liable for ₱32,000.00, a decision affirmed by the Court of Appeals (CA) with a modified interest computation.
ISSUE
Whether the CA committed reversible error in affirming petitioner Diaz’s civil liability to respondent Arcilla.
RULING
The Supreme Court denied the petition, upholding Diaz’s civil liability. The Court clarified that an acquittal in a criminal case based on reasonable doubt does not extinguish civil liability if a preponderance of evidence establishes the obligation. Here, the civil standard was met. The acknowledgment receipt, duly identified and offered in evidence by Arcilla, constituted prima facie proof of the consignment transaction and the debt. Diaz’s denial of the receipt and her claim of having signed only blank documents for prior, settled transactions were deemed bare allegations unsupported by evidence. She failed to present any proof to rebut the presumptions of regularity and genuineness attached to the signed document.
The evidence preponderated in favor of Arcilla, establishing Diaz’s failure to account for the merchandise or its proceeds. However, the Court modified the interest rate in accordance with Bangko Sentral ng Pilipinas Circular No. 799, Series of 2013. Diaz was ordered to pay Arcilla ₱32,000.00 with legal interest at 6% per annum from July 28, 1998 (date of extrajudicial demand) until full payment.