Title
Artates y Gallardo vs. People
Case
G.R. No. 235724
Decision Date
Mar 11, 2020
Maria Artates misrepresented her influence to secure Jun Pablico's PNP entry, receiving P50,000. Failed promises led to her arrest for estafa; SC affirmed conviction, modified penalty, and awarded damages.
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Case Digest (G.R. No. 235724)

Facts:

  1. Recruitment and Misrepresentation

    • On November 16, 2003, Maria Lourdes Artates y Gallardo (petitioner) approached Patrocinia Pablico and her son, Jun Pablico, at Filart Shoe Store in Vigan City. Maria claimed that her husband, PO3 Edmundo Artates, who was detailed as security for then Governor Luis "Chavit" Singson, could facilitate Jun's entry into the Philippine National Police (PNP).
    • Maria asked for money to cover expenses such as uniforms, medical examinations, neuro-examinations, and a "blow-out." She assured Patrocinia that Jun did not need to undergo a medical examination because her husband had influence within the PNP.
    • From November 16, 2003, to February 20, 2004, Maria received a total of P50,000.00 or more from Patrocinia and Jun.
  2. Failed Promise and Discovery

    • Despite receiving the money, Maria failed to fulfill her promise. Jun was later informed that the PNP recruitment period had already ended.
    • Patrocinia and Jun confronted Maria at her residence, only to discover that Maria was no longer living with her husband, PO3 Edmundo Artates, who denied any knowledge of Jun's application.
  3. Entrapment Operation

    • On February 20, 2004, Patrocinia and Jun reported the matter to the Vigan Police Station. A police entrapment operation was arranged, during which Patrocinia handed Maria marked money. Maria was subsequently arrested, and the marked money was recovered from her.
  4. Criminal Charges

    • An Information for estafa under Article 315, paragraph 2(a) of the Revised Penal Code (RPC) was filed against Maria. She pleaded not guilty during her arraignment.
  5. Trial and Defense

    • During the trial, Maria denied the allegations, claiming that Patrocinia was her friend and co-worker. She alleged that Patrocinia had given money to her husband, Edmundo, and that the case against her was filed because Patrocinia was afraid to confront Edmundo, who was an influential police officer.

Issue:

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Ruling:

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Ratio:

  1. Elements of Estafa

    • The crime of estafa by means of deceit requires:
      • A false pretense or fraudulent act.
      • The false pretense must be made prior to or simultaneously with the commission of the fraud.
      • The offended party must have relied on the false pretense and been induced to part with their money or property.
      • The offended party must have suffered damage as a result.
  2. Credibility of Witnesses

    • The trial court's findings on the credibility of witnesses are accorded great respect, especially when affirmed by the Court of Appeals. Minor inconsistencies in testimonies do not undermine credibility if the overall narrative is coherent and believable.
  3. Legality of Arrest and Admissibility of Evidence

    • The legality of an arrest and the admissibility of evidence obtained during an entrapment operation are irrelevant if the crime is proven by independent evidence.
  4. Modification of Penalty

    • Republic Act No. 10951, which adjusted the penalties under the RPC, applies retroactively. Thus, the penalty for estafa involving P50,000.00 is reduced to arresto mayor in its maximum period to prision correccional in its minimum period.
  5. Damages and Interest

    • Actual damages must be proven with reasonable certainty. Interest on the amount awarded is imposed to compensate for the loss of use of the money.


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