Dina C. Buenaflor v. Office of the Secretary of Justice Through Hon. Regional Prosecutor Janet Grace B. Dalisay-Fabrero

Summary

Petitioner Dina Buenaflor filed criminal complaints for Estafa with Abuse of Confidence and Other Deceits against bank and guarantee corporation officials, alleging she paid PHP950,000 to settle loans in 1989 but the payment was not credited. The Supreme Court denied her petition for review, affirming lower courts' dismissal of the criminal complaint on grounds of prescription and lack of probable cause. The Court found that Buenaflor's claims lacked credibility and sufficient evidence, noting it was improbable for a businesswoman to pay such a substantial amount without demanding a receipt. The Court ruled that all potential crimes had prescribed, with the prescriptive period beginning in 1993 when the guarantee corporation filed a collection case against Buenaflor, putting her on notice that her alleged payment was not credited. The Court also directed petitioner's counsel to explain why they should not be sanctioned for filing a frivolous case.