Monday, February 27, 2012

Sia vs. People

Facts: Jose Sia, president and GM of Metal Manufacturing Company of the Phil., on behalf of said company, obtained delivery of 150 cold rolled steel sheets valued at P71,023.60 under a trust receipt agreement. Said sheets were consigned to the Continental Bank, under the express obligation on the part of Sia of holding the sheets in trust and selling them and turning over the proceeds to the bank. Sia, however, allegedly failed and refused to return the sheets or account for the proceeds thereof if sold, converting it to his own personal use and benefit. Continental Bank filed a complaint for estafa against Sia. The trial court and CA ruled against Sia.

Issue: Whether or not Sia, acting as President of MMCP, may be held liable for estafa 

Held: Sia was acquitted. CA decision is reversed. 

An officer of a corporation can be held criminally liable for acts or omissions done in behalf of the corporation only where the law directly requires the corporation to do an act in a given manner. In he absence of a law making a corporate officer liable for a criminal offense committed by the corporation, the existence of the criminal liability of he former may not be said to be beyond doubt. Hence in the absence of an express provision of law making Sia liable for the offense done by MMCP of which he is President, as in fact there is no such provision under the Revised Penal Code, Sia cannot be said to be liable for estafa. 




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1 comments: on "Sia vs. People"

Anonymous said...

Just a suggestion/request- please make the distinct identity of the case clearer so as not to be confused with other cases. For example, for this case of "Sia vs People", there is also a case of the same name and a BP 22 case. Maybe you can put the year, the GR #, SCRA #, or anything else that will make it easier to identify quickly.

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