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CASE TITLE PETITIONER RESPONDENT FACTS OF THE CASE STATEMENT OF

AND THE CASE


NUMBER
28 Sia v. Court of Jose O. Sia Court of Appeals Sia (President and General CFI – convicted Sia.
Appeals and the People of Manager of the Metal
the Philippines Manufacturing of the CA – affirmed with
121 SCRA 655 Philippines, Inc.) applied for the modification that
(1983) and was granted a LC with Sia is to indemnify the
the Continental Bank to offended party to the
cover the importation of 100 extent after marginal
pieces of Safe-Deposit Locks deposit was deducted.
with keys amounting to
P1,979.06.Sia thereafter SC – granted the
executed a TR in favor of petition for review on
Continental Bank, agreeing to certiorari, and
hold the goods in trust for the acquitted Sia without
said bank. prejudice to the
institution of a civil
When the said trust receipt action against Metal
became due and Manufacturing of the
demandable, the Metal Philippines, Inc.
Manufacturing of
thePhilippines, Inc. failed to
pay or deliver the
merchandise to the Bank
despite the latter's demands.
An information for estafa was
thus filed with the CFI of
Manila against Sia in his
capacity as President and
General Manager.
The decision in Sia v. People calls for a reversal of the CA’s appealed judgment, thereby resulting in Sia’s
acquittal.

It should be pointed out however, that if the acts herein involved occurred after 29 January 1075, Siawould be
criminally liable for estafa under paragraph l(b), Article 315 of the Revised Penal Code, pursuant to thefollowing
provisions of PD 115—
Sec. 13. Penalty clause.—The failure of an entrustee to turn over the proceeds of the sale of thegoods,
documents or, instruments covered by a trust receipt to the extent of the amount owing to theentruster
or as appears in the trust receipt or to return said goods, documents or instruments if theywere not
sold or disposed of in accordance with the terms of the trust receipt shall constitute the
crime of estafa, punishable under the provisions of Article Three hundred and fifteen, paragraph
oneof Act Numbered Three thousand eight hundred and fifteen, as amended, otherwise known as
theRevised Penal Code. If the violation or offense is committed by a corporation,
partnership,association or other juridical entities, the penalty provided for in this Decree shall be
imposed upon
the directors, officers, employees or other officials or persons therein responsible for the
offense,without prejudice to the civil liabilities arising from the criminal offense.

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