Ibanez v. People

Summary

Supreme Court reversed estafa conviction of Danilo S. Ibañez who was accused of misappropriating P647,960.00 from property sale proceeds. The Court held that the Memorandum of Agreement clearly established a contract of sale, not agency, making petitioner a buyer rather than an agent holding proceeds in trust. Under the parol evidence rule, the written agreement's express terms controlled, preventing contradiction by extrinsic evidence. Since no agency relationship existed, petitioner could not be convicted of estafa through misappropriation as he owned the property as vendee. The Court distinguished between criminal liability (absent) and civil obligation under the parties' Amicable Settlement, ordering payment of the unpaid balance with interest. This case clarifies the essential elements of estafa and the importance of accurately characterizing contractual relationships in determining criminal liability.