G.R. No. 196231 - Gonzales III vs. Office of the President of the Philippines

In 2008, Ma. Anacleta Rachelle Paguirigan (Anacleta) introduced herself as general manager of AJ Construction and Development Company to Elizabeth Delos TriAos (Elizabeth).
Anacleta and Elizabeth executed a contract to sell a lot located at Spud St., East Fairview, Quezon City, explicitly stating Anacleta represented vendor and owner Alfredo A. Rosanna.
Elizabeth tendered PHP 100,000 as initial payment. The sale did not materialize as Alfredo sold to another buyer.

In 2009, a contract to sell for a different lot at Winston St., East Fairview was executed between Anacleta and Elizabeth.
Elizabeth paid PHP 780,000 to Anacleta but the sale failed due to bank loan denial.
Elizabeth demanded a refund totaling PHP 880,000; Anacleta issued bounced checks.

On February 26, 2016, Elizabeth charged Anacleta with two counts of estafa through false pretenses under Article 315, paragraph 2(a) of the Revised Penal Code.
The First Information (Criminal Case No. 16-03867) accused Anacleta of falsely presenting herself as licensed developer and owner/general manager to obtain PHP 100,000.
The Second Information (Criminal Case No. 16-03868) involved a similar charge regarding PHP 780,000.
Anacleta pleaded not guilty, claiming legitimate management and representation roles, admitted payments receipt but attributed failure to external factors and bank loan denial.

On July 20, 2018, the RTC convicted Anacleta for the first estafa charge and acquitted her for the second.
The RTC held Anacleta liable to return PHP 780,000 with interest.

The CA affirmed the conviction, ruling Anacleta falsely represented ownership and power to transfer property.
It held the right to be informed was not violated as the offense proved was included in that charged.

Anacleta sought review alleging denial of right to be informed of the charge as she was convicted of facts not alleged (ownership misrepresentation vs. developer status).
The People opposed, maintaining correct conviction.

Whether Anacleta's constitutional right to be informed of the nature and cause of the accusation was violated by convicting her of factual allegations not stated in the information.
Whether the prosecution sufficiently proved the elements of estafa through false pretenses or fraudulent acts beyond reasonable doubt.
Whether the variance doctrine applies to the differences between allegations in the information and proof adduced at trial.
The extent of Anacleta's criminal and civil liabilities based on the evidence.