G.R. No. 228704 , December 02, 2020
Diosa Arrivas, Petitioner, vs. Manuela Bacotoc, Respondent.

FACTS

Petitioner Diosa Arrivas and respondent Manuela Bacotoc were long-time acquaintances engaged in the business of buying and selling jewelry. On July 23, 2003, Arrivas, claiming to have a client, received from Bacotoc a men’s diamond ring valued at P75,000.00 under a trust receipt. The receipt stipulated that Arrivas would sell the ring on commission, remit the proceeds, or return the unsold item within two days. After the period lapsed, Arrivas failed to return the ring or remit payment. Despite subsequent promises to pay in installments and a partial payment of P20,000.00 allegedly made by Arrivas, she failed to settle the full amount. Bacotoc sent a formal demand, which went unheeded, leading to the filing of an estafa case under Article 315, paragraph 1(b) of the Revised Penal Code.
Arrivas presented a different version, claiming she merely signed the receipt as an accommodation for two prospective buyers, Virgie Valencia and Letty Espinosa, who had unsettled accounts with Bacotoc. She asserted that the transaction was not for her benefit and that she made partial payments from her own pocket after the buyers failed to materialize. The Regional Trial Court convicted Arrivas of estafa, a decision affirmed with modifications by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming petitioner Diosa Arrivas’s conviction for the crime of Estafa under Article 315, paragraph 1(b) of the Revised Penal Code.

RULING

The Supreme Court denied the petition and affirmed the conviction. The elements of estafa under Article 315, paragraph 1(b) are: (1) the offender receives money, goods, or other personal property in trust or on commission; (2) the offender misappropriates or converts the same to her own use or benefit; and (3) such act causes damage or prejudice to another. All elements were proven beyond reasonable doubt. The trust receipt established that the ring was received in trust by Arrivas, with the obligation to return it or its proceeds. Her failure to account for the property after demand constituted conversion or misappropriation, causing financial prejudice to Bacotoc.
The Court rejected Arrivas’s defense that she acted merely as an accommodating party. The clear terms of the trust receipt, which she voluntarily signed, established her personal obligation. Her subsequent actions, including making partial payments, were deemed admissions of her liability and inconsistent with her claim of being a mere guarantor. The factual findings of the lower courts, which found her version less credible, are generally binding on the Supreme Court. The penalty imposed by the CA, applying the indeterminate sentence law and adjusting the penalty under Republic Act No. 10951 , was affirmed as correct.