People vs. Carulasdulasan, et al., (G.R. No.

L-6408, May 24, 1954)

● Doctrine
Estafa wherein there is a clear and deliberate intent to defraud the injured party as per Art. 315, sub. 1, (b)
of the RPC

● Facts
The defendants, Carulasdulasan and Becarel being the tenants of Almagro had an express agreement to
share one-half of whatever the former’s products they could harvest in the land. Upon harvesting 600 kg
of Abaca, the defendants didn’t comply in giving 300 kg to their landlord and upon the non-compliance
of the demand of their obligation, both defendants were criminally charged with estafa and has to pay
damages of PHP 330.00. The defendants seek to dismiss the case because of lack of merit.

● Issue/s
W/n the trial court erred in granting the motion due to lack of merit.

● Ruling
No, the trial court did not err in granting the motion due to lack of merit. According to Art. 315, sub. 1,
(b) of the RPC, misappropriation of goods received by the offender in trust or commission merits to
estafa. In this case, provided that the defendant failed to fulfill their obligation to share half of their
harvest based on their agreement with the tenant and was used for their personal use and benefit
constitutes estafa.