G.R. No. 199975 - Arriola vs. People

Luis T. Arriola was charged before the RTC of Makati with Estafa under Article 315(2)(a) of the Revised Penal Code for allegedly defrauding Ingeborg De Venecia Del Rosario of PHP 437,000 by representing that he was authorized to sell a parcel of land owned by Paciencia G. Candelaria in Tagaytay City.
Arriola pleaded not guilty, moved to quash (denied), underwent pre-trial, and the prosecution presented Del Rosario and Atty. Mary Ann Roa as witnesses. Arriola’s direct testimony was stricken when he failed to appear for cross-examination.

Del Rosario testified that in April–June 2001 Arriola showed her a purported authorization letter, a certified copy of TCT No. 33184, a fax from Candelaria, and a draft Deed of Absolute Sale, inducing her to pay PHP 100,000 earnest money and PHP 337,000 balance for the lot.
Arriola failed to deliver the original documents, issued dishonored checks, and only later issued a check from a closed account. Del Rosario then contacted Candelaria in Australia, who denied any sale or authorization.

The RTC convicted Arriola on April 17, 2007, sentencing him to an indeterminate term (minimum 4 years, 2 months, 1 day prision correccional; maximum 20 years reclusion temporal) and ordering restitution of PHP 437,000. Arriola paid the amount on October 15, 2007.
On appeal, the CA on August 5, 2011 affirmed conviction, deleted the restitution order, and denied reconsideration on January 3, 2012. Arriola then filed a Rule 45 petition before the Supreme Court.

Whether the CA erred in admitting and relying on hearsay evidence concerning Candelaria’s statements.
Whether Arriola’s return of the purchase price plus interest established good faith and negated criminal liability.
Whether the CA should have applied the equipoise doctrine in favor of Arriola given conflicting versions of authority to sell.