G.R. No. 172500 - Aricheta vs. People

In an Information dated 7 October 1996, petitioner Lilibeth Aricheta was charged with the crime of Estafa.

The allegation centered on a transaction involving a parcel of land (approximately 48 square meters) in Barangay Bagumbong, Novaliches, Caloocan City, which petitioner purportedly acquired from the National Housing Authority (NHA) through a deed of sale with mortgage.

It was alleged that petitioner, knowing that she had already disposed of her rights over the said property, fraudulently sold the same to private complainant Margarita Vasquez by executing a Deed of Sale with Assumption of Mortgage on 27 April 1994, in which she represented herself as the absolute owner.

Private complainant, Margarita Vasquez, agreed to pay P50,000.00 and assume a sum of P191,075.00 with the NHA in connection with the transaction.

The deed contained a warranty clause stating that the vendor (petitioner) was the absolute owner and would defend the vendee against any lawful claims by third parties.

After payment and execution of the document, private complainant encountered problems in securing a gate pass from the NHA, which subsequently led her to discover that the property was occupied by a third party.

Private complainant’s efforts to resolve the issue included making personal inquiries, receiving information from the NHA and local barangay, and addressing a demand letter sent to petitioner—efforts which ultimately went unanswered by the petitioner.

On 13 January 1997, when arraigned, petitioner pleaded not guilty; the pre-trial conference was terminated on 18 February 1997.

Evidence was presented by private complainant and corroborated by witnesses, including testimony from Norita A. de Guzman, who attested to being present during the transaction and observing the payment made by the private complainant.

During trial, petitioner testified that the property was awarded through a raffle and that she had only mortgaged, not sold, the property to the private complainant. She further explained that a previous transaction involving a mortgage with Margarita Galang had been an antecedent matter, which however did not affect her standing as owner according to NHA records.

The Regional Trial Court of Manila convicted petitioner of Estafa on 25 September 2000 and imposed an indeterminate penalty of imprisonment along with accessory costs.

On appeal, the Court of Appeals affirmed the conviction with modifications, adjusting the penalty but still upholding the finding of guilt.

Petitioner's appeal to the Supreme Court brought into focus whether the prosecution had proven beyond reasonable doubt the element of deceit—specifically, that petitioner, by falsely representing herself as the absolute owner, had already transferred ownership of the property prior to the transaction with the private complainant.

Whether the prosecution established beyond reasonable doubt that petitioner made a false representation that she was the absolute owner of the property at the time of the transaction with private complainant.
Whether the evidence on record sufficiently demonstrated that the property had been previously encumbered, transferred, or mortgaged to another party, thereby negating petitioner’s claim of ownership during the sale.
Whether the failure to prove that the alleged prior sale or mortgage occurred justifies acquitting petitioner of Estafa under Article 315(2)(a) of the Revised Penal Code.