Coson v. People
REITERATIONFacts
The Antecedents: Jesus V. Coson (petitioner), Chairman and CEO of Good God Development Corporation (GGDC), was involved in a series of transactions with Atty. Nolan Evangelista (private complainant). Initially, GGDC borrowed ₱2,522,000.00 from private complainant, using a property covered by TCT No. 252245 as collateral. Subsequently, GGDC, through petitioner, obtained another loan of ₱4,784,000.00 from private complainant, secured by TCT No. 261204, which covered a property adjacent to GGDC's main property. A Memorandum of Agreement (MOA) was executed, stipulating that petitioner would borrow TCT No. 261204 to secure a loan from the Home Development Mutual Fund (PAG-IBIG Fund) to pay private complainant. Petitioner issued 11 postdated checks as security. GGDC later obtained a developmental loan from PAG-IBIG Fund not exceeding ₱30,000,000.00. A portion of this loan, ₱9,000,000.00, was released. Petitioner failed to pay private complainant or return TCT No. 261204 as agreed, leading to a complaint for Estafa under Article 315, par. 1(b) of the Revised Penal Code. Procedural History: The Regional Trial Court (RTC) of Dagupan City, Branch 44, found petitioner guilty beyond reasonable doubt of Estafa. The Court of Appeals (CA) affirmed the RTC's decision in toto. Petitioner's Motion for Reconsideration was denied by the CA. The Petition: Petitioner filed a Petition for Review, arguing that he could not be held liable for Estafa because the obligation to return TCT No. 261204 was conditional and extinguished upon the approval of the PAG-IBIG Fund loan. He also contended that there was no misappropriation or conversion of property for personal use, as GGDC owned the property and the loan proceeds, and private complainant was aware of the purpose of the loan. Petitioner asserted that his relationship with private complainant was merely that of debtor and creditor, and the remedy for the uncollected debt was civil, not criminal.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's decision finding the petitioner guilty beyond reasonable doubt of Estafa under Article 315, par. 1(b) of the Revised Penal Code. Whether the petitioner misappropriated or converted the Title Certificate of Title (TCT) No. 261204 or the proceeds of the PAG-IBIG Fund loan for his personal use and benefit.
Ruling
The Supreme Court reversed and set aside the Decision and Resolution of the Court of Appeals. It entered a new judgment acquitting petitioner Jesus V. Coson of the crime charged.
Ratio Decidendi
On the issue of Estafa under Article 315, par. 1(b) of the Revised Penal Code: The Court found that the essential elements of Estafa under Article 315, par. 1(b) were not sufficiently proven. While the petitioner received TCT No. 261204 under an obligation to return it or use it to secure a loan for payment, the Court found that the property and the loan proceeds belonged to GGDC, not to the petitioner personally or to the private complainant. The MOA and the Deed of Real Estate Mortgage were executed by petitioner in his capacity as an officer of GGDC, and GGDC was the registered owner of the property covered by TCT No. 261204. The loan from PAG-IBIG Fund was a developmental loan to finance GGDC's housing project, a fact known to the private complainant. Therefore, any misappropriation or conversion of the TCT or loan proceeds would prejudice GGDC, not the private complainant. The Court reiterated that misappropriation or conversion refers to the disposition of another's property as if it were one's own or devoting it to an unauthorized purpose, which did not occur here as the property and loan proceeds were corporate assets used for a corporate project. On the issue of misappropriation or conversion for personal use: The Court held that there was no misappropriation or conversion by the petitioner to his own personal use, benefit, or advantage. The petitioner acted on behalf of GGDC, which owned the title and was the recipient of the loan proceeds. The purpose of the loan from both the private complainant and PAG-IBIG Fund was for GGDC's housing business, a fact that the private complainant was aware of. The Court noted that the RTC made several factual errors, including misstating the owner of TCT No. 261204 and the amount of the mortgage loan. Furthermore, the Court found that the petitioner presented evidence, including the Loan Agreement and MOA, showing that the TCT was to be cancelled and replaced with individual titles for the lots, which was corroborated by the Register of Deeds' testimony. The letters from petitioner to private complainant also indicated the latter's awareness of and interest in GGDC's housing venture. Consequently, the Court concluded that the obligation was purely civil, and the private complainant's remedy was a civil action, not a criminal one for Estafa.
Main Doctrine
The crime of Estafa under Article 315, par. 1(b) of the Revised Penal Code requires the receipt of property in trust or under an obligation to deliver or return the same, followed by misappropriation or conversion to the prejudice of another, and a demand for its return. However, if the property received in trust or the loan proceeds are owned by a corporation, and the transaction is for the benefit of the corporation, the aggrieved party for any misappropriation or conversion is the corporation itself, not the private complainant, and the remedy for an uncollected debt is a civil action.