• This case involves a criminal complaint for Estafa filed nearly 30 years after the alleged crime. The Supreme Court affirmed the dismissal of the complaint, ruling that the crime had long prescribed. The Court held that the prescriptive period began not when the complainant claimed to have "discovered" the fraud decades later, but when she was put on notice of the alleged non-payment through a collection suit filed against her in 1993. Furthermore, the Court found no probable cause, deeming the complainant's story of paying a substantial sum of money in cash without demanding a receipt as inherently improbable.

• The Loan and Alleged Payment: In 1987, Dina Buenaflor and her husband took out loans of PHP 950,000.00 from UCPB. Buenaflor claims that in 1989, she personally paid this amount in cash to the bank manager, Edmond Bernardo, but was not issued a receipt.
• Subsequent Events: Believing the loan was unpaid, UCPB collected from its guarantor, Quedancor, in 1991. In 1993, Quedancor filed a collection suit against Buenaflor, which was eventually dismissed in 2007.
• Criminal Complaint: After various other proceedings, Buenaflor filed a criminal complaint for Estafa in January 2019, alleging she only discovered the "fraud" in 2017 when she learned Quedancor could no longer produce the original loan documents.

• Prosecutor's Office (OCP & RPO): The City and Regional Prosecutors dismissed the complaint, primarily on the ground that the crime had prescribed, having been filed almost 30 years after the alleged payment.
• Court of Appeals (CA) Ruling: The CA upheld the dismissal, agreeing that the crime had prescribed and that there was no probable cause, as Buenaflor's claim lacked credibility.
• Appeal to the Supreme Court: Buenaflor filed a Petition for Review, insisting the prescriptive period only started in 2017.

• When does the prescriptive period for Estafa begin to run? Is it from the actual commission or from the complainant's claimed date of "discovery" of the fraud?
• Is there probable cause for Estafa when the complainant's core allegation (a large, unreceipted cash payment) is inherently improbable?

The Supreme Court DENIED the petition and AFFIRMED the dismissal of the criminal complaint.

• On Prescription: The crime had clearly prescribed. The prescriptive period started in 1993 when Quedancor filed a collection suit against Buenaflor. This event served as a clear and unequivocal notice to her that her alleged 1989 payment was not honored. Filing the complaint in 2019 was well beyond the 10 or 15-year prescriptive period for Estafa.
• On Probable Cause: There was no probable cause. Buenaflor's claim of paying PHP 950,000 in cash without demanding a receipt was deemed inherently improbable and contrary to the ordinary experience of a businesswoman. Her evidence was self-serving and lacked independent corroboration.

• Prescription of Crimes (Art. 91, RPC): The prescriptive period for a crime commences from the day on which the crime is discovered by the offended party, the authorities, or their agents. "Discovery" happens when the offended party has actual or constructive notice of circumstances sufficient to know a crime was committed.
• Probable Cause: An executive determination of probable cause requires credible evidence that conforms to common human experience. Allegations that are inherently improbable or lack independent corroboration may be dismissed.
• Estafa with Abuse of Confidence: This crime requires that the offender receives money or property in trust or on commission, creating a fiduciary relationship. Payment of a loan to a bank manager does not create such a relationship; the manager receives the money on behalf of the bank.