Lim v. People · G.R. L-34338

Petitioner: Lim
Respondent: People
Citation: G.R. No. L-34338
Court: Supreme Court
Decided: November 21, 1984

Summary

Criminal case where petitioner Lourdes Valerio Lim was prosecuted for estafa after receiving tobacco worth P799.50 from complainant under an agreement but only paying P240.00. The key legal issue was whether the agreement constituted an agency to sell or an outright sale. The Supreme Court upheld the conviction, ruling that the written agreement clearly established an agency relationship requiring petitioner to turn over proceeds as soon as the tobacco was sold. Since ownership never transferred to petitioner, she could not claim the defense that would preclude estafa liability. The Court found the obligation immediately demandable upon sale and rejected petitioner's argument that Article 1197 of the Civil Code applied to extend the payment period.

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Contract of Agency in the Philippines

By the Intellegal Editorial Board · November 21, 1984

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