Case Summary (G.R. No. 199975)
Petitioner, Respondent, and Applicable Law
Petitioner: Luis T. Arriola
Respondent: People of the Philippines
Offense Charged: Estafa under Revised Penal Code (RPC) Article 315(2)(a)
Constitutional Basis: 1987 Philippine Constitution
Implementing Rules: Rules of Court, Rule 130 (Hearsay) and Rule 45 (Certiorari)
Key Dates and Procedural History
April–June 2001: Alleged fraudulent sale negotiations and receipt of ₱437,000
August 2, 2001: Notarization of deed
May–June 2002: Issuance and dishonor of checks
July 11, 2002: Another dishonored check
April 17, 2007: RTC conviction with indeterminate penalty
October 15, 2007: Partial payment of ₱437,000 by petitioner
August 5, 2011: CA decision affirming conviction, deleting indemnity award
January 3, 2012: CA resolution denying reconsideration
February 24, 2020: Supreme Court decision
Trial Court Decision
The RTC found petitioner guilty beyond reasonable doubt of estafa by false pretenses under Article 315(2)(a) RPC. It held that Arriola falsely claimed authority to sell Candelaria’s lot, produced a defective authorization letter, bogus fax transmission, and a deed with suspect signatures to induce Del Rosario to pay ₱437,000. He was sentenced to an indeterminate term of 4 years, 2 months, and 1 day of prision correccional to 20 years of reclusion temporal, plus restitution.
Court of Appeals Ruling
The CA affirmed the RTC, ruling that all elements of estafa by deceit were satisfied: false pretenses, reliance, damage. It held that Del Rosario’s testimony of calls with Candelaria was an independently relevant statement, not barred by the hearsay rule. The CA deleted the restitution clause, noting petitioner had already paid Del Rosario, and denied his plea of lack of due process and reliance on good faith.
Issues on Review
- Admissibility of hearsay evidence (calls with Candelaria)
- Existence of petitioner’s good faith based on repayment of proceeds
- Application of the equipoise doctrine due to alleged conflicting versions
Supreme Court’s Analysis on Hearsay and Independently Relevant Statements
The Court held that Del Rosario’s and counsel’s testimonies regarding statements by Candelaria were admitted as independently relevant statements. They were not offered to prove truth but to establish that such statements were made, proving petitioner’s lack of authority and reinforcing the totality of circumstances. Cross-examination tested their perception, and ancillary evidence (telephone records, White Pages, statutory declaration) corroborated the context.
Findings on Falsity of Representations and Documentary Fabrication
The Supreme Court examined the authorization letter, fax transmission, and deed. It observed that the authorization merely permitted receipt of payment, not a special power of attorney to sell real property, as required by Articles 1874 and 1878(5) of the Civil Code. Signature comparisons revealed stark discrepancies, raising serious doubts about their genuineness. Phone calls with Candelaria confirmed she never authorized any sale and was not in Manila to sign documents.
Application of Estafa Elements
All four elements under Article 315(2)(a) RPC were satisfied:
• False pretense: Claim of authority to sell supported by fabricated documents.
• Timing: Representations preceded or coincided with receipt of payment.
• Reliance: Del Rosario parted with ₱437,000 based on petitioner’s assurances.
• Damage: Complainant’s money was misapplied for petitioner’s benefit.
Return of Money, Good Faith, and Equipoise Rule
The retur
...continue readingCase Syllabus (G.R. No. 199975)
Procedural Posture
- Petition for Review on Certiorari under Rule 45 of the Rules of Court (G.R. No. 199975, February 24, 2020) challenges:
- The August 5, 2011 Decision and January 3, 2012 Resolution of the Court of Appeals in CA-G.R. CR No. 31338.
- The April 17, 2007 Decision of the Regional Trial Court (RTC), Branch 146, Makati City, convicting Petitioner of Estafa under Article 315(2)(a) of the Revised Penal Code.
- Arriola appealed from his conviction and sentence, arguing lack of due process, reliance on hearsay, absence of damage, and a valid defense of good faith.
- The Court of Appeals denied relief, affirmed the RTC conviction, and deleted the P437,000 indemnity order as already paid by Petitioner.
Facts of the Case
- In April–June 2001, Petitioner, a licensed real estate broker, induced private complainant Ingeborg De Venecia Del Rosario to pay P437,000 for a parcel of land in Tagaytay City purportedly owned by Pasiencia G. Candelaria.
- Petitioner presented:
- An “Authorization” letter allegedly from Candelaria authorizing him to receive payment for the lot.
- A certified copy of Transfer Certificate of Title No. 33184 in Candelaria’s name.
- A fax transmission from Candelaria in Australia instructing Petitioner to process documentation.
- A Deed of Absolute Sale purportedly signed by Candelaria and notarized.
- Del Rosario paid P100,000 as earnest money and P337,000 balance on June 28, 2001, signing the Deed of Absolute Sale on Petitioner’s assurances.
- Repeated requests for original documents yielded only notarized copies; Petitioner promised and issued dishonored checks (June 20, 2002; June 20, 2002 for P524,000+P5,000) when Del Rosario demanded refund.
- Del Rosario independently contacted Candelaria via Brisbane White Pages and learned Candelaria never authorized any sale.
- Del Rosario filed Estafa charges. Petitioner failed to appear for his cross-examination; his direct testimony was stricken.
Ruling of the Regional Trial Court
- Found all elements of Estafa by false pretenses (Article 315(2)(a), RPC) proven beyond reasonable doubt:
- Petitioner falsely claimed authority to sell Candelaria’s land.
- Del Rosario relied on those representations and parted with P437,000.
- Petitioner applied the funds to his own benefit, causing prejudice to Del Rosario.
- Co