In Marissa Ceniza-Manantan v. The People of the Philippines, the Supreme Court affirmed the conviction of Marissa Ceniza-Manantan for estafa, specifically for misappropriating jewelry received in trust. The ruling underscores that estafa can be proven through circumstantial evidence, such as the failure to return items held in trust upon demand, and that a single credible witness can suffice for conviction. This case highlights the importance of fulfilling obligations in trust agreements and serves as a reminder that even verbal contracts carry legal weight, particularly in cases involving misappropriation.

From Jewelry to Justice: Did a Broken Promise Lead to Estafa?

The case revolves around an agreement between Alberto Carilla, a jeweler, and Marissa Ceniza-Manantan, where Manantan was to act as Carilla’s agent in selling jewelry worth P1,079,000. Manantan received the jewelry in trust, with the obligation to sell them within two weeks and remit the proceeds, or return the jewelry if unsold. When Manantan failed to either remit the proceeds or return the jewelry, Carilla made repeated demands. In response, Manantan issued postdated checks, which were subsequently dishonored due to a closed account. This led Carilla to file a criminal complaint for estafa under Article 315, paragraph 1(b) of the Revised Penal Code.

Manantan denied the accusations, claiming the checks were merely borrowed by her sister-in-law, Regina Manantan-Vizconde, and that she had no direct transaction with Carilla. However, the Regional Trial Court (RTC) found Manantan guilty, a decision later affirmed with modification by the Court of Appeals. The Supreme Court was then tasked to determine whether the prosecution successfully proved Manantan’s guilt beyond reasonable doubt and whether Manantan was deprived of her right to an effective counsel.

The Supreme Court emphasized that the quality of testimony, not the number of witnesses, determines the truth. The Court found Carilla’s testimony to be credible and consistent with his complaint-affidavit. This consistency, coupled with the dishonored checks and demand letters, formed a solid basis for the conviction. The Court reiterated that the findings of fact by the trial court, especially when affirmed by the appellate court, are generally binding. Manantan’s defense relied heavily on denials, which the Court found insufficient to rebut the prosecution’s evidence. The Supreme Court underscored the principle that positive testimony on affirmative matters holds greater evidentiary weight than bare denials.

The elements of estafa under Article 315, paragraph 1(b) of the Revised Penal Code, are crucial in understanding the conviction. These elements are: (a) receiving money, goods, or property in trust or on commission; (b) misappropriating or converting such property or denying its receipt; and (c) causing prejudice to another. In this case, the Supreme Court found that all elements were present. Manantan received the jewelry in trust, failed to remit the proceeds or return the jewelry, and her actions prejudiced Carilla.

Article 315 of the Revised Penal Code provides the legal framework for understanding the crime of estafa:

ART. 315. Swindling (estafa). – Any person who shall defraud another by any of the means mentioned hereinbelow shall be punished by:

x x x x

1. With unfaithfulness or abuse of confidence, namely:

x x x x

(b) By misappropriating or converting, to the prejudice of another, money, goods or any other personal property received by the offender in trust, or on commission, or for administration, or under any other obligation involving the duty to make delivery of, or to return the same, even though such obligation be totally or partially guaranteed by a bond; or by denying having received such money, goods, or other property.

The Court clarified that the absence of a written agreement does not negate the existence of a contract. Verbal contracts are valid as long as there is a meeting of the minds. The misappropriation was evident in Manantan’s failure to account for the jewelry or its proceeds, despite demands from Carilla. The Court also noted that denying receipt of the jewelry, when evidence suggested otherwise, constituted estafa. The Court explained that the terms “misappropriate” and “convert” imply using another’s property as one’s own or devoting it to a purpose different from that agreed upon. In an agency agreement for selling jewelry, failing to return the jewelry upon demand is considered evidence of conversion.

Manantan’s defense argued that her counsel’s incompetence denied her due process. She claimed her counsel failed to adequately cross-examine Carilla and present a strong defense. The Supreme Court acknowledged the general rule that mistakes and negligence of counsel bind the client. However, it also recognized exceptions where the counsel’s mistake is so great that the client is prejudiced or when the counsel is grossly negligent. After reviewing the records, the Court found that while her counsel may have made mistakes, there was no evidence of gross negligence that would warrant a new trial. Her counsel did cross-examine Carilla, present Manantan as a witness, and object to the prosecution’s evidence.

Regarding the penalty, the Supreme Court affirmed the Court of Appeals’ decision, which imposed an indeterminate sentence of four years and two months of prision correccional as minimum to twenty years of reclusion temporal as maximum. This was based on the amount defrauded, which greatly exceeded P22,000.00, warranting the imposition of the maximum penalty. The Court also sustained the award of actual damages of P1,079,000.00 to Carilla, representing the value of the misappropriated jewelry. The penalty prescribed by Article 315 is composed of two periods, and Article 65 of the Revised Penal Code requires dividing the time included in the penalty into three equal portions.

The Court emphasized that failure to account for property held in trust raises a presumption of misappropriation. Manantan’s bare denials were insufficient to overcome this presumption. In sum, the Supreme Court found no reversible error in the lower courts’ decisions and affirmed Manantan’s conviction for estafa.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution successfully proved beyond reasonable doubt that Marissa Ceniza-Manantan committed estafa by misappropriating jewelry she received in trust from Alberto Carilla. Additionally, the court examined if Manantan’s right to effective counsel was violated.
What is estafa under Article 315, paragraph 1(b) of the Revised Penal Code?	Estafa under this provision involves misappropriating or converting money, goods, or property received in trust, on commission, or under any obligation involving the duty to deliver or return it, to the prejudice of another. This includes denying having received such property.
What are the elements needed to prove estafa in this case?	The elements are: (1) receiving money, goods, or property in trust; (2) misappropriating or converting the property or denying its receipt; and (3) causing prejudice to another. All three elements must be proven beyond reasonable doubt for a conviction.
Is a written contract necessary to prove a trust agreement?	No, a written contract is not always necessary. Verbal contracts are valid as long as there is a meeting of the minds between the parties. The testimony of a credible witness can establish the existence of a trust agreement.
What weight does a single witness’s testimony carry?	The testimony of a lone witness, if found positive and credible by the trial court, is sufficient to support a conviction, especially when the testimony bears the earmarks of truth and sincerity. The quality of the testimony is more important than the number of witnesses.
What is the significance of dishonored checks in estafa cases?	Dishonored checks can serve as evidence of the accused’s failure to pay for the goods or property received in trust. It supports the claim that the accused misappropriated or converted the property to their own use.
What is the effect of a counsel’s mistake or negligence on a client’s case?	Generally, a counsel’s mistakes and negligence bind the client. However, there are exceptions where the counsel’s mistake is so great that the client is prejudiced or when the counsel is grossly negligent, which may warrant a new trial.
What was the sentence imposed on Manantan for estafa?	Manantan was sentenced to an indeterminate penalty of four years and two months of prision correccional as the minimum to twenty years of reclusion temporal as the maximum. She was also ordered to pay P1,079,000.00 as actual damages to Carilla.
What does it mean to misappropriate or convert property in the context of estafa?	To misappropriate or convert property means to use another’s property as if it were one’s own or to devote it to a purpose different from that agreed upon. This includes failing to return the property upon demand or failing to account for it.

This case serves as a clear illustration of how the elements of estafa are applied in cases involving breach of trust. It underscores the importance of fulfilling obligations in trust agreements and highlights the legal consequences of misappropriating property. This case reinforces the need for individuals to uphold their fiduciary duties and the potential repercussions of failing to do so.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MARISSA CENIZA-MANANTAN vs. THE PEOPLE OF THE PHILIPPINES, G.R. NO. 156248, August 28, 2007