Case Digest (G.R. No. 246265-66)
Facts:
Maybel A. Umpa v. People of the Philippines, G.R. Nos. 246265-66, March 15, 2021, Supreme Court Third Division, Lopez, J., writing for the Court.Petitioner Maybel A. Umpa, at the time a Records Officer I of the Land Registration Authority (LRA), was criminally charged along with co-accused Carlito Castillo following a complaint by private complainant Lory D. Malibiran that petitioner fraudulently induced him to pay for documents needed to title a 7.2-hectare parcel in Rodriguez, Rizal. Malibiran consulted Umpa in February 2010, paid P20,000 as a research fee, and later — upon Umpa’s assurance that she could secure the approved plan, tax declaration and certificate of title — paid an additional P620,000 (for a total figured by the courts as P640,000), which Umpa failed to deliver or return.
Malibiran pursued administrative relief with the LRA (hearing June 15, 2011), then filed criminal charges with the Office of the Ombudsman, which on March 23, 2012 found probable cause and filed two Informations before the Regional Trial Court (RTC) of Quezon City, Branch 85 (docketed R‑QZN‑13‑01427 and R‑QZN‑13‑01428). Castillo was arraigned and later benefited from an Affidavit of Desistance executed by Malibiran (November 20, 2014), leading the RTC to dismiss the case against Castillo; Umpa, who was at large and later arraigned (August 11, 2015), was tried in absentia until apprehended and convicted.
On November 10, 2017 the RTC rendered a Joint Decision finding Umpa guilty beyond reasonable doubt of estafa under Article 315(2)(a) of the Revised Penal Code (RPC) and of violating Section 3(e) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act), sentencing her and ordering restitution. The Sandiganbayan affirmed on December 20, 2018 but modified the estafa penalty in light of R.A. No. 10951; its judgment increased the total actual damages to P640,000 and left other penalties as imposed. The Sandiganbayan denied Umpa’s motion for reconsideration on April 2, 2019.
Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court before the Court, contesting the credibility of Malibiran, arguing inconsistent aff...(Subscriber-Only)
Issues:
- Does the petition present substantial questions warranting review under Rule 45?
- Did the prosecution prove beyond reasonable doubt the elements of estafa under Article 315(2)(a) RPC against petitioner?
- Did the prosecution prove beyond reasonable doubt petitioner’s violation of Section 3(e) of R.A. No. 3019?
- Are the penalties imposed appropriate, and is modification required (including rest...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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