CASE DIGEST : UCIA MANUEL Y CADIZ v. PEOPLE GR No. 213640, Apr 12, 2023 GAERLAN

FACTS : Petitioner Lucia Manuel was charged with estafa under Article 315(2)(d) of the Revised Penal Code for allegedly issuing ten postdated Philippine National Bank (PNB) checks amounting to ₱889,606.00 as payment for live chickens purchased from Ebot's Farm. The prosecution alleged that petitioner, a regular customer of the farm, issued the checks knowing that her account had already been closed. When the checks were dishonored for the reason "Account Closed" and petitioner failed to settle her obligation despite repeated demands, criminal complaints for estafa and ten counts of violation of B.P. Blg. 22 were filed. During trial, the prosecution presented farm employees and the PNB branch manager, who confirmed that petitioner signed and dated the checks, although the payee's name and amounts were written by another person.

For her defense, petitioner admitted issuing the checks but claimed that she signed them in blank, leaving the payee and amount to be filled in later as security for her purchases from Ebot's Farm, which she asserted was owned by Alex Uson and not private complainant Flordeliza Uy. She argued that she had no transaction with Uy and emphasized that the prosecution failed to present Uy as a witness. Nevertheless, the RTC found petitioner guilty of estafa and ordered her to indemnify Uy, while the Court of Appeals affirmed the conviction, holding that the prosecution sufficiently established all the elements of estafa through the testimonies of its witnesses despite the non-presentation of the private complainant, modifying only the penalty imposed.

ISSUE : WON the CA erred in denying the appeal

HELD : The Supreme Court granted the petition and held that the prosecution failed to prove petitioner's guilt for estafa beyond reasonable doubt. While affidavits of desistance are generally viewed with suspicion, the Court ruled that the Affidavit of Desistance executed by private complainant Flordeliza Uy, together with her testimony in the related B.P. Blg. 22 cases, constituted exceptional circumstances that cast serious doubt on the prosecution's evidence. Uy expressly admitted that she had no transaction with petitioner, that she did not know why the checks were issued in her name, and that there was no legal or factual basis for the criminal charges. Her testimony also contradicted the prosecution's claim that she owned Ebot's Farm, the alleged source of the live chickens purchased by petitioner.

The Court found that these contradictions created reasonable doubt as to the existence of the underlying transaction and the essential elements of deceit and damage required for estafa under Article 315(2)(d) of the Revised Penal Code. Since the prosecution failed to establish that petitioner issued the checks to defraud Uy or that Uy suffered damage as a result, petitioner's constitutional presumption of innocence prevailed. Accordingly, the Court reversed the decisions of the lower courts, acquitted petitioner on the ground of reasonable doubt, and ruled that her civil liability arising from the alleged offense was likewise extinguished because the supposed obligation itself was shown not to exist.