G.R. No. 147782 - Aquino vs. Paiste

On March 14, 1991, petitioner Juanita A. Aquino, Elizabeth Garganta, and a woman named "Adeling" visited respondent Teresita B. Paiste at her residence in Tondo, Manila. The children of petitioner and respondent were classmates, establishing a social connection.
Petitioner introduced to respondent a proposal to purchase a gold bar purportedly owned by a certain Arnold, an Igorot. A sample gold bar was shown to respondent, who agreed to go to a pawnshop with them in Tondo for testing—which confirmed its genuineness. However, respondent stated she had no money to buy it.
Despite this, petitioner and Garganta returned the next day to persuade respondent to visit Angeles City, Pampanga, to meet Arnold and see the gold bar in person. Arnold valued the gold bar at PhP 60,000. Respondent again stated she had no money, but petitioner convinced her of the investment opportunity.

On March 16, 1991, petitioner, Garganta, and Adeling went back to respondent's house to press the purchase, but failed to convince her.
On March 17, 1991, they returned saying the price was reduced to PhP 10,000 and persuaded respondent to again go to Angeles City with them to meet Arnold. Arnold feigned refusal of the PhP 10,000 offer, insisting instead on PhP 50,000.
Ultimately, on March 18, 1991, respondent bought the gold bar for PhP 50,000. Petitioner handled the cash, re-counted it, wrapped it in newspaper, and delivered it to Arnold.

On March 19, respondent had the gold bar tested again and was informed it was fake.
On the same day, respondent confronted petitioner, who denied involvement and insisted on locating Garganta.
On March 27, 1991, under the auspices of the National Bureau of Investigation – NCR (NBI-NCR), petitioner and respondent signed an amicable settlement where petitioner acknowledged fault and agreed to pay respondent half of the swindled amount (PhP 25,000) in monthly installments. The document included a waiver of petitioner’s right to counsel, though she was provided with counsel (Atty. Gordon S. Uy).
On April 6, petitioner brought Garganta to respondent’s house and was identified in the presence of officials as the seller of the fake gold bar. Garganta was taken into custody.

Respondent filed a criminal complaint against petitioner, Garganta, and three others for estafa, charging conspiracy and fraud through false representations about the gold bar.
Only petitioner was arraigned and pleaded not guilty. Trial commenced with testimonies from respondent, witnesses, and petitioner herself. Documentary evidence included the amicable settlement.
On July 16, 1998, the Manila RTC convicted petitioner of estafa, sentencing her to 5–9 years imprisonment, ordering indemnity with 12% interest, and payment of court costs. The court found conspiracy proven and gave weight to the amicable settlement as an implied admission of guilt.
Petitioner appealed to the Court of Appeals (CA), which on November 10, 2000, affirmed the conviction, highlighting the active participation of petitioner in the crime and the admissibility of the amicable settlement despite averred threat claims. The CA denied reconsideration on April 6, 2001.

Whether the amicable settlement executed by petitioner during the custodial investigation at the NBI is admissible as evidence despite petitioner’s claim it was signed under threat and without proper waiver of rights.
Whether the conspiracy between petitioner and her co-accused to commit estafa was sufficiently proven to convict petitioner beyond reasonable doubt.
Whether the investigation conducted by the NBI and the waiver of petitioner’s right to counsel complied with constitutional and procedural requirements.
Whether petitioner actively participated in the commission of the offense of estafa.