G.R. No. 122955 - St. Theresa's School of Novaliches Foundation vs. National Labor Relations Commission

The case originated with a Petition for Review on Certiorari under Rule 45 filed by Jerry Dean A. Palaoag (petitioner) challenging the decision of the Court of Appeals (CA).
The assailed CA Decision dated November 26, 2020, affirmed a Regional Trial Court decision from August 16, 2018, which found petitioner and Maricar Buyo a.k.a. Ma. Christina Yamada Banzon (accused Buyo) guilty of Estafa under paragraph 2(a) of Article 315 of the Revised Penal Code, as amended by Republic Act No. 10951.
A subsequent Resolution dated June 4, 2021, denying petitioner’s motion for reconsideration is also part of the record.

The incident arose from an alleged fraudulent transaction in which petitioner, accused Buyo, and a third person (Jane Doe) were implicated.

On or about September 11, 2011, in Olongapo City, petitioner and accused Buyo were involved in presenting a woman who falsely identified herself as “April Rose Hautakorpi” (referred to as Jane Doe).
The presentation was made to Alberto M. Balauag, with the claim that the woman possessed a Nissan Sentra with Plate No. TOO 297 and that it could serve as collateral.

Balauag, relying on the false representations—including a driver’s license, certificate of registration, and an official receipt purportedly under the name April Rose Hautakorpi—agreed to lend money.
Due to a shortage of cash, Balauag provided only Php160,000.00 on the spot, while the balance was to be sent later via courier.
Jane Doe signed acknowledgment receipts for both the amount given and the total purported loan, thereby inducing Balauag to part with his money.

After the transaction, Balauag discovered on September 14, 2011, that the Nissan Sentra was missing from his garage and later learned that the car had been taken by individuals operating a black Hyundai Accent.

The Hyundai Accent was registered under the name of April Rose Marquez-Hautakorpi, owner of a rent-a-car business.
Investigations revealed that the car was part of Marquez-Hautakorpi’s fleet and had been rented during the period surrounding the transaction.

Further revelations from the investigation indicated that the person pretending to be April Rose Hautakorpi was actually Jane Doe, and the documents presented were fake.
When Balauag realized the misrepresentation, he contacted petitioner, who promised to help but failed to locate Jane Doe.

At arraignment, petitioner, accused Buyo, and Marquez-Hautakorpi pleaded “not guilty.”

Accused Buyo later failed to appear during pre-trial proceedings, with her counsel claiming that she had jumped bail.

Prosecution evidence primarily relied on the testimony of Balauag and the circumstantial evidence regarding the fraudulent presentation and subsequent misrepresentation.
The RTC and later the CA found that petitioner and accused Buyo conspired with Jane Doe in defrauding Balauag.

The RTC rendered a decision finding petitioner and accused Buyo guilty of Estafa, sentencing them to an indeterminate penalty and ordering petitioner to indemnify Balauag for Php160,000.00.
On appeal, the CA affirmed the RTC decision, relying on the essential participation of petitioner—namely, his act of introducing Jane Doe—and his alleged personal knowledge of her identity.

Petitioner argued that the proof of conspiracy was not established beyond reasonable doubt.
He asserted that merely introducing Jane Doe to Balauag did not constitute an overt act of conspiracy or active participation in the fraudulent scheme.

Whether the Court of Appeals erred in finding petitioner guilty of conspiring to commit Estafa against Balauag.

Whether mere introduction of Jane Doe to Balauag can be equated with active participation in the fraudulent scheme.
Whether the elements of conspiracy, particularly the requirement of an overt act in furtherance of a common criminal design, were sufficiently established against petitioner.
Whether guilt has been proven beyond reasonable doubt considering the prosecution’s reliance on circumstantial evidence and the absence of concrete evidence that petitioner had personal knowledge or intent to defraud.