G.R. No. 224673 - Rivac vs. People

Cecilia Rivac (petitioner) was charged with Estafa under Article 315 (1)(b) of the Revised Penal Code (RPC) before the Regional Trial Court (RTC) of Laoag City, Branch 14.
The private complainant was Asuncion C. FariAas, who allegedly consigned jewelry to Rivac for sale.

On August 4, 2007, Rivac received jewelry valued at P439,500.00 from FariAas under a consignment agreement to sell within seven (7) days and remit proceeds or return unsold jewelry by August 11, 2007.
Rivac purportedly failed to remit proceeds or return the jewelry despite demands, instead offering a parcel of land (OCT No. 0-936) as partial payment, which FariAas refused due to a land dispute.
The prosecution charged that Rivac willfully misappropriated and converted the jewelry to her personal use, causing damages to FariAas.

Rivac pleaded "not guilty," claiming the transaction was a loan, not consignment; she purportedly gave the land title as collateral for a P150,000.00 loan from FariAas.
She testified to paying interest but not the full loan, and alleged that FariAas demanded payment and threatened foreclosure of the collateral.

RTC found Rivac guilty beyond reasonable doubt, sentencing her to imprisonment and ordering payment of P439,500.00 to FariAas.
The RTC gave probative weight to the consignment agreement bearing Rivac’s signature and rejected her loan defense, applying the parol evidence rule.
The court ruled that FariAas only had the OCT because Rivac offered it as partial payment, which was declined.

Before the judgment became final, Rivac moved to reopen the case to present additional witnesses, including FariAas and Atty. Ma. Valenie Blando, to prove the true nature of the transaction.
The RTC partly granted the motion to reopen, allowing FariAas to testify but denied Atty. Blando’s testimony for lack of justification for non-presentation during the original trial.
In her testimony on reopening, FariAas "clarified" that the consignment document never became effective because she did not allow Rivac to take the jewelry due to unpaid loan obligations.
The RTC affirmed its judgment, deeming the recantation as unreliable and suspect, noting FariAas had multiple prior opportunities to clarify her statements.

The CA affirmed the conviction but criticized the RTC’s reopening of the case after promulgation of judgment, likening it to an improper new trial.
On the merits, the CA found all elements of Estafa proven, upholding the conviction despite FariAas’s recantation, which it considered unreliable.
The CA denied Rivac’s motion for reconsideration, prompting this petition for review.

Whether the RTC properly reopened the case after promulgation of judgment.
Whether the elements of Estafa under Article 315 (1)(b) RPC were proven beyond reasonable doubt to uphold Rivac’s conviction.