Facts:

In the case of Luis T. Arriola v. People of the Philippines, G.R. No. 199975, the petitioner, Luis T. Arriola, was charged with estafa under Section 315, Paragraph 2(a) of the Revised Penal Code before the Regional Trial Court (RTC), Branch 146 of Makati City. The criminal information dated February 11, 2003, indicated that from April to June 2001, Arriola allegedly defrauded Ingeborg De Venecia Del Rosario by falsely representing himself as the authorized real estate broker of Paciencia G. Candelaria, who owned a parcel of land in Tagaytay City. Arriola persuaded Del Rosario to purchase the said property, leading her to pay a total of ₱437,000.00 based on his fraudulent representations.

During the trial, it was revealed that Arriola provided a fabricated authorization letter and other fake documents to Del Rosario, which falsely supported his claims. Del Rosario made incremental payments, culminating in a receipt issued by Arriola. However, subsequent attempts to solidify the s

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Facts:

Background and Criminal Charge

• Luis T. Arriola, a licensed real estate broker, was charged with Estafa under Section 315, Paragraph 2(a) of the Revised Penal Code, alleging that he committed fraud by misrepresenting his authority in a property transaction.
• The criminal proceedings arose from a transaction involving Ingeborg De Venecia Del Rosario, who was induced to pay a total of P437,000.00 for a parcel of land in Tagaytay City purportedly owned by Pasencia G. Candelaria.

Transaction and Representations

• Arriola represented himself as the duly authorized real estate broker for Candelaria and presented several documents to induce the sale:
• An Authorization Letter, allegedly granting him authority only to receive payment, but misrepresented as authorizing him to sell.
• A certified copy of Transfer Certificate of Title (TCT) No. 33184, purportedly demonstrating Candelaria’s ownership.
• A fax transmittal apparently from Candelaria, supporting his authority.
• Based on these representations, Del Rosario:
• Paid an earnest money of P100,000.00.
• Settled the remaining balance of P337,000.00, evidenced by a Receipt of Payment issued by Arriola.
• Executed a Deed of Absolute Sale prepared by Arriola, which was notarized after Del Rosario signed, albeit with only photocopies being initially provided.

Delivery of Documents and Subsequent Developments

• Del Rosario repeatedly requested the original documents (especially the TCT) to complete the sale, but only received a notarized copy of the Deed and tax receipt copies.
• Arriola promised in a December 17, 2001 letter to return the full amount on January 7, 2002, a promise he later reneged on.
• Del Rosario’s attempts to secure reimbursement were met with dishonored checks:
• A check dated June 20, 2002 was dishonored due to a closed account.
• Another check, issued on July 11, 2002, along with a cash component, was dishonored for insufficient funds.

Trial Court Proceedings and RTC Decision

• Arriola pleaded not guilty, but his case was largely undermined by his repeated absences, including failure to attend cross-examination hearings.
• The Regional Trial Court (RTC), after evaluating the pre-trial and trial evidence, convicted Arriola on April 17, 2007.
• The RTC found that:
• Arriola falsely represented his authority to sell Candelaria’s lot.
• Del Rosario was induced to part with her money relying on these misrepresentations.
• The elements of Estafa were met, given the fraudulent nature of the representations and the damage incurred (P437,000.00).
• Arriola was sentenced to an indeterminate penalty ranging from four (4) years, two (2) months and one (1) day of prision correccional (as minimum) to twenty (20) years of reclusion temporal (as maximum) and was ordered to return the amount.

Court of Appeals Proceedings

• On appeal, Arriola contended:
• His conviction was based on inadmissible hearsay evidence.
• He was denied his right to full participation and cross-examination, breaching due process.
• His subsequent reimbursement attempts demonstrated good faith which should mitigate liability.
• The equipoise doctrine should have favored his defense given conflicting representations regarding his authority.
• The Court of Appeals (CA):
• Affirmed the RTC’s conviction, rejecting the admissibility challenge against the hearsay evidence by explaining that such evidence was used to establish that the statements were indeed made.
• Found that Del Rosario’s testimony, together with corroborative evidence (telephone records, white pages, and statutory declarations), confirmed the fraudulent representations.
• Deleted the indemnity amount given Arriola’s subsequent payment yet maintained his criminal liability.

Documentary and Witness Evidence on Falsification

• Arriola’s presented documents (Authorization, fax transmission, and Deed of Absolute Sale) displayed glaring discrepancies:
• The purported signatures of Candelaria differed markedly across the documents, indicating potential forgery or misrepresentation.
• The Authorization failed to meet the legal requirement of a special power of attorney needed for the sale of real property.
• Phone calls involving Del Rosario, Arriola’s counsel, and Candelaria further confirmed that:
• Candelaria never authorized the sale of her property.
• The inconsistencies in the documents and testimonies substantiated Arriola’s fraudulent conduct.

Arriola’s Failure to Exercise His Right to Testify

• Arriola’s direct testimony was stricken off for his repeated failures to appear at scheduled hearings, particularly for his cross-examination, which further weakened his case.
• His absences deprived him of the opportunity to contest the prosecution’s evidence effectively.

Issue:

Reliability and Admission of Hearsay Evidence

• Whether the CA erred in giving weight to hearsay evidence regarding Candelaria’s statements as relayed by Del Rosario.
• Whether such hearsay, when considered as independently relevant (merely to prove that the statements were made), was admissible.

Due Process and the Defendant’s Right to Participate

• Whether Arriola’s failure to participate fully in the proceedings, particularly in cross-examination, infringed on his right to due process.
• Whether this failure contributed to his conviction by undermining his ability to challenge the evidence presented against him.

Good Faith and the Effect of Reimbursing the Payment

• Whether returning the amount to Del Rosario, despite being done after conviction, constituted good faith that might exonerate or mitigate Arriola’s criminal liability.
• How the act of reimbursement impacted the assessment of the fraudulent transaction and resultant damage.

Application of the Equipoise Doctrine

• Whether the equipoise doctrine should have been applied in favor of Arriola given the conflicting accounts of his authority to sell the property.
• Whether the doctrine could have created sufficient doubt as to his intent and undermined the prosecution’s case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)