G.R. No. L-11589, October 26, 1916
THE UNITED STATES, plaintiff-appellee, vs. LORENZO ADOR DIONISIO, defendant-appellant.

FACTS:
The defendant, Lorenzo Ador Dionisio, rented a bicycle from Liberato Garcia on February 14, 1915, agreeing to return it in four days and to pay a rental rate of ₱1.50 per day. Dionisio failed to return the bicycle and falsely denied having rented it, claiming instead that he merely guaranteed its return by another person. He was convicted of estafa (swindling) by the trial court. The court sentenced him to four months and one day of arresto mayor, ordered him to return the bicycle or pay its value (₱678), and additionally required him to pay accrued rental fees at ₱1.50 per day from February 14, 1915, until the bicycle’s return or the start of his sentence.

ISSUE:
Whether the trial court erred in including in the criminal judgment the payment of accrued bicycle rental fees as part of the civil liability arising from the crime of estafa.

RULING:
The Supreme Court AFFIRMED the conviction but MODIFIED the civil aspect of the judgment. The Court held that the accrued rental fees do not constitute civil indemnity (perjuicios) recoverable under Article 119 of the Penal Code in a criminal case for estafa. The rental debt arose from the contract of lease and is independent of the crime of estafa, which is based on the fraudulent failure to return the bicycle. The only civil liability recoverable in the criminal case is the return of the bicycle or payment of its value. The rental fees must be pursued in a separate civil action. Thus, the portion of the trial court’s judgment ordering payment of accrued rentals was deleted. The penalty and the order to return the bicycle or pay its value were sustained.