G.R. No. 32455 - People vs. Santiago

The People of the Philippine Islands filed a complaint against Gervasio Santiago, who was then convicted by the Court of First Instance of Manila on the charge of estafa.
Santiago, also known by the alias R. R. Revilla, had a long criminal history, having been previously convicted of estafa nine times, with his last sentence completed in April 1927.

Santiago, presenting himself as an agent of the Radium Ore Ravigator Co., visited the residence of Jesus Pereira located at 507 Sto. Sepulcro Street, Manila.
He offered to sell a filter of the said company. Although Pereira initially declined the purchase, Santiago persisted by mentioning that he had already sold 499 filters and only required one more sale to win a prize of P500.
Santiago also asserted that the filter was valued at P40, which led Pereira to eventually agree to buy the filter.
Pereira, having only P20 available at the time, was told by Santiago that the P20 would serve as the first installment of the payment.

Jesus Pereira prepared check No. 394664 amounting to P20 against the Bank of the Philippine Islands, and during the process, rather than filling in Santiago’s name, Santiago instructed Pereira to write “cash” on the check.
Santiago then issued a receipt (marked Exhibit A) promising to deliver the filter later that same day upon return.
A few hours later, Santiago returned to the store, purportedly seeking a recommendation to visit another store owned by one Guerra in M. H. del Pilar, where he would supposedly sell a filter.
Given that this was Pereira’s first encounter with Santiago, Pereira opted instead to produce a letter acknowledging the purchase rather than providing a personal recommendation.
Santiago again reiterated that he would return in the afternoon to provide the filter. However, as the day progressed without Santiago’s appearance, Pereira grew suspicious.

Pereira contacted the office of the Radium Ore Ravigator Company to inquire about an employee named R. R. Revilla. The company confirmed that no such employee existed, thus arousing Pereira’s suspicions.
Prompted by the irregularities, Pereira reported the matter to the police station and handed over Exhibit A as evidence.
At the police station, upon reviewing photographs in the rogues’ gallery, Pereira identified Santiago (alias R. R. Revilla), who was known to have multiple aliases.
Subsequently, the offended party also requested the Bank of the Philippine Islands to suspend payment on the check, which was ultimately never presented for payment.

The evidence presented by Pereira and the circumstances surrounding the transaction established the commission of the crime of estafa beyond a reasonable doubt.
Santiago testified in his own defense, denying all allegations. He claimed that during the incident, he was employed as a checker by the Robert Dollar Company.
However, his criminal record and the corroborative testimony of the offended party negated his defense, supporting the prosecution's case.

The facts were held to constitute the crime of estafa under Article 535, number 1, and penalized by Article 534, number 1, of the Penal Code, as amended by Act No. 3244.
Due to the involvement of a negotiable instrument (the check) that, although not cashed, caused temporary financial prejudice, the actions of Santiago were deemed sufficient to fulfill the requisite elements of estafa.

Santiago’s prior convictions for the same crime, including the recent completion of a sentence in April 1927, rendered him an habitual criminal.
As per Section 1, subsection (d) of Act No. 3397, his habitual criminal status warranted an additional penalty of twenty-one years’ imprisonment.

Whether the evidence presented at trial was sufficient to convict Santiago of the crime of estafa.
The legitimacy of relying on the temporary financial prejudice resulting from the negotiable check even though the check was not cashed.

The trial court allegedly erred in convicting Santiago based on the proofs presented by the prosecution.
The trial court purportedly erred in its failure to acquit Santiago of the charge, considering the circumstances and the nature of the transaction.

The relevance and weight to be given to Santiago’s previous estafa convictions in determining his culpability and penalty.
Whether his status as an habitual criminal should result in an aggravated sentence.