Metrobank vs. Secretary of Justice Raul M. Gonzales, Et. Al.-2
Metrobank vs. Secretary of Justice Raul M. Gonzales, Et. Al.-2
Metrobank vs. Secretary of Justice Raul M. Gonzales, Et. Al.-2
Issue:
Whether or not probable cause exists for the prosecution of private respondents for
the crime of Estafa in relation to P.D. No. 115?
Held:
Yes. The Supreme Court found the petition to be meritorious. It concluded that there
was probable cause to warrant the prosecution of private respondents for estafa
According to the Court, considering the enormous value of the transaction involved, it
was highly improbable to mistake trust receipt documents for a contract of loan when
the heading thereon printed in bold and legible letters reads: Trust Receipts.
Although it said that it was not prejudging the case on the merits, the Court stated
that by merely glancing at the documents submitted by petitioner entitled Trust
Receipts and the arguments advanced by private respondents, it was convinced that
there was probable cause to file the case and to hold them for trial. As found in the
Complaint-Affidavit of petitioner, private respondents were charged with failing to
account for or turn over to petitioner the merchandise or goods covered by the trust
receipts or the proceeds of the sale thereof in payment of their obligations thereunder.
The following pieces of evidence adduced from the affidavits and documents
submitted before the City Prosecutor are sufficient to establish the existence of
probable cause.
First, the trust receipts bearing the genuine signatures of private respondents; second,
the demand letter of petitioner addressed to respondents; and third, the initial
admission by private respondents of the receipt of the imported goods from petitioner.
Prescinding from the foregoing, we conclude that there is ample evidence on record to
warrant a finding that there is a probable cause to warrant the prosecution of private
respondents for estafa. It must be once again stressed that probable cause does not
require an inquiry into whether there is sufficient evidence to procure a conviction. It
is enough that it is believed that the act or omission complained of constitutes the
offense charged.
That private respondents did not sell the goods under the trust receipt but allowed it to
be used by their sister company is of no moment. The offense punished under
Presidential Decree No. 115 is in the nature of malum prohibitum. A mere failure to
deliver the proceeds of the sale or the goods, if not sold, constitutes a criminal offense
that causes prejudice not only to another, but also more to the public interest. Even
more incredible is the contention of private respondents that they did not give much
significance to the documents they signed, considering the enormous value of the
transaction involved. Thus, it is highly improbable to mistake trust receipt documents
for a contract of loan when the heading thereon printed in bold and legible letters
reads: Trust Receipts. We are not prejudging this case on the merits. However, by
merely glancing at the documents submitted by petitioner entitled Trust Receipts
and the arguments advanced by private respondents, the Supreme Court was
convinced that there was probable cause to file the case and to hold them for trial.