Elizabeth Eusebio-Calderon v. People

Summary

Elizabeth Eusebio-Calderon was charged with three counts of estafa for issuing bad checks totaling P363,150 to family members in exchange for cash loans. The Regional Trial Court convicted her but the Court of Appeals acquitted her on reasonable doubt while maintaining civil liability for the full amounts including stipulated interest. The Supreme Court affirmed the acquittal but modified the civil liability, ruling that verbal interest agreements are void under Article 1956 of the Civil Code. The Court reduced her obligation to the principal loan amounts (P307,500 total) plus legal interest at 12% per annum from the demand date. This case establishes that while criminal liability for estafa requires proof beyond reasonable doubt, civil liability for loans can be established by preponderance of evidence even after acquittal, and that interest agreements must be in writing to be enforceable.