US v. Dominguez

Summary

This 1903 criminal case clarified the elements of estafa under the Penal Code regarding depositaries. The Supreme Court held that a depositary cannot be convicted of estafa merely for refusing to return deposited property; the prosecution must prove actual appropriation or diversion of the deposit. The Court distinguished between denial of receipt (which constitutes estafa) and refusal to return (which requires additional proof of appropriation). The decision established important precedent regarding the burden of proof in estafa cases involving deposits, emphasizing that criminal liability requires more than mere breach of civil obligations.