Case Summary (G.R. No. L-64508)
Nature of the Charge and the Information
Arriola was charged with Estafa under Article 315, paragraph 2(a) of the Revised Penal Code for allegedly inducing Del Rosario to pay P437,000.00 as full purchase price for a parcel of land in Tagaytay by falsely representing that he was the authorized broker and was authorized by Candelaria to sell and receive payment for the property.
Prosecution Evidence Presented at Trial
The prosecution’s case rested on Del Rosario’s testimony and corroboration by Atty. Mary Ann B. Roa. Documentary and testimonial evidence included: an Authorization purportedly signed by Candelaria; a certified copy of Transfer Certificate of Title No. 33184; a fax transmission allegedly from Candelaria; a Deed of Absolute Sale presented by Arriola (bearing an alleged signature of Candelaria and a witness); receipts reflecting payment of P437,000; two checks subsequently issued and dishonored; and telephone contact by Del Rosario and by Atty. Roa with Candelaria in Brisbane, who denied authorizing the sale.
Procedural Posture: Defense Failures and Stricken Testimony
Arriola pleaded not guilty, filed a Motion to Quash which the RTC denied, and participated in pre-trial. However, his direct testimony was struck off the record and his right to present evidence was deemed waived after he repeatedly failed to appear for cross‑examination despite warnings and multiple reschedulings. The record cites specific missed cross‑examination dates and court warnings.
RTC Findings and Judgment
The RTC found the prosecution proved guilt beyond reasonable doubt and convicted Arriola of Estafa under Article 315(2)(a). The trial court concluded that Arriola made fraudulent representations that induced Del Rosario to part with P437,000.00. The RTC imposed an indeterminate sentence (initially stated as four years, two months, one day of prision correccional minimum to twenty years reclusion temporal maximum) and ordered return of P437,000.00. Arriola paid P437,000.00 to Del Rosario on October 15, 2007, and filed an appeal.
Court of Appeals Ruling
The CA affirmed the RTC’s conviction, concluding the elements of Estafa by deceit were present. It held that the contested statements were not pure hearsay because they were independently relevant and supported by corroborative circumstantial evidence (telephone records, Brisbane White Pages listing, and a statutory declaration regarding the White Pages). The CA also found no due process violation because Arriola had actively participated and had been warned as to consequences of non-appearance. Because Arriola had already paid Del Rosario, the CA deleted the monetary indemnity portion of the RTC’s judgment. The CA decision (Aug. 5, 2011) and denial of reconsideration (Jan. 3, 2012) were appealed to the Supreme Court.
Issues Presented to the Supreme Court
Arriola raised three primary assignments of error: (1) the CA erred in giving credence to hearsay evidence; (2) the CA erred in not recognizing his good faith based on his attempt and eventual payment to return the purchase price plus interest; and (3) the CA erred in failing to apply the equipoise doctrine (arguing conflicting versions should be resolved in favor of the accused).
Standard of Review and Constitutional/Procedural Framework
The Supreme Court noted the general doctrine of deference to trial court factual findings but recognized a jurisprudential exception where lower courts’ findings are conclusions without citation of specific evidence. Given the 2020 decision date, the 1987 Constitution provides the governing framework for due process and fairness issues raised on appeal. The Court confined its review to whether the evidentiary bases and reasoning adequately supported the RTC and CA conclusions and addressed gaps in the lower courts’ discussion on the falsity of representations and documentary evidence.
Hearsay Rule and the Doctrine of Independently Relevant Statements
The Court analyzed Section 36, Rule 130 (hearsay exclusion) and applied the doctrine of independently relevant statements as expounded in People v. Umapas: when the fact that a statement was made (rather than the truth of its contents) is itself relevant, the hearsay rule does not bar its admission. Del Rosario’s and Atty. Roa’s testimony regarding telephone conversations with Candelaria were admissible to prove that Candelaria had denied authorizing Arriola to sell the land and that such denials were communicated to the complainant or her counsel. Those statements were circumstantially relevant and tested by cross‑examination where applicable.
Scrutiny of the Documentary Evidence and Authority to Sell
The Supreme Court closely examined the documents Arriola presented: the Authorization, the fax transmission, and the Deed of Absolute Sale. The Authorization merely authorized Arriola to receive payment on behalf of Candelaria and did not constitute the special power of attorney required to confer authority to sell immovable property under Civil Code provisions. The fax likewise spoke only to processing documentation and did not evidence conveyancing authority. The Deed purportedly bearing Candelaria’s signature raised credibility issues. The Court observed glaring, prima facie inconsistencies among the signatures on the three documents that were sufficiently evident to cast doubt on their authenticity without requiring a handwriting expert.
Corroborative Telephone Testimony and Circumstantial Matrix
Telephone conversations between Del Rosario and Candelaria and between Atty. Roa and Candelaria corroborated the prosecution’s account that Candelaria denied any authorization to sell and denied signing the Deed. Those independently relevant statements, together with the documentary inconsistencies and evidence that Candelaria was abroad at relevant times, formed a coherent circumstantial matrix showing Arriola lacked authority and that his representations were false when made.
Consequences of the Accused’s Failure to Testify and Be Cross‑Examined
Arriola’s repeated nonappearance for cross‑examination led the RTC to strike his direct testimony; the Supreme Court observed that when a party’s conduct prevents completion of cross‑examination, the uncompleted testimony becomes incompetent. The accused’s failure to present and defend his testimony substantially weakened any conflicting account and precluded effective rebuttal of the prosecution’s circumstantial proofs.
Application of the Elements of Estafa (Article 315(2)(a))
The Court articulated the four elements of Estafa by deceit under Article 315(2)(a): (1) a false pretense or fraudulent representation as to agency, etc.; (2) that such false pretense was made prior to or simultaneously with the fraud; (3) the offended party relied on the false pretense and parted with money or property; and (4) the offended party suffered damage. The record showed that Arriola made false representations about his authority, those representations preceded and induced Del Rosario’s payment, and Del Rosario suffered loss of P437,000.00. Thus, the elements were satisfied beyond reasonable doubt.
Return of the Purchase Price and the Good Faith Defense
The Co
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Case Caption, Citation, and Nature of Proceeding
- Supreme Court Second Division decision in G.R. No. 199975, February 24, 2020; reported 871 Phil. 585; 117 OG No. 44, 10317 (November 1, 2021).
- Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the Court of Appeals' August 5, 2011 Decision and January 3, 2012 Resolution in CA-G.R. CR No. 31338.
- Petitioner: Luis T. Arriola. Respondent: People of the Philippines. Decision penned by Justice Hernando (with a concurrence noted from Perlas-Bernabe (Chairperson), A. Reyes, Jr., Inting, and Delos Santos, JJ.).
Antecedent Facts and Charge (Information)
- Information filed February 11, 2003 in RTC, Makati City (Branch 146) charging Arriola with Estafa under Article 315, paragraph 2(a) of the Revised Penal Code.
- Alleged period of offense: April to June 2001, in Makati City.
- Criminal allegation: Arriola, by false manifestations and fraudulent representations, purportedly held himself out as the authorized real estate broker/agent of one Pasencia (also spelled Pasiencia/Paciencia) G. Candelaria, had authority to sell and receive payments for a parcel of Tagaytay City land, and could facilitate issuance of a new Transfer Certificate of Title in the complainant’s name.
- As a result of these representations, complainant Ingeborg De Venecia Del Rosario allegedly paid Arriola a total of ₱437,000.00 as full payment for the land; the prosecution alleged Arriola knew the representations were false and used the money for his own benefit to the damage of Del Rosario.
- Arriola pleaded not guilty at arraignment.
Prosecution’s Factual Narrative (Evidence Presented)
- Complainant Del Rosario testified she met Arriola in 2001, learned of an adjacent lot to a property she already owned, and became interested in acquiring Candelaria’s lot to build a therapy center.
- Arriola allegedly showed Del Rosario: (a) an Authorization Letter purportedly from Candelaria authorizing Arriola to receive payment; (b) a certified copy of TCT No. 33184 showing Candelaria as title owner; (c) a fax transmittal allegedly from Candelaria in Australia authorizing Arriola to transact and receive payment; and (d) a Deed of Absolute Sale purportedly signed by Candelaria and witnessed by Sister Adela Arabia.
- Del Rosario initially paid ₱100,000.00 earnest money, then the balance of ₱337,000.00 for a total of ₱437,000.00; Arriola issued a Receipt of Payment dated June 28, 2001 and prepared the Deed which Del Rosario signed.
- Original documents were not delivered despite requests; Del Rosario only received a notarized copy of the Deed and copies of tax receipts appended to a letter dated September 22, 2001.
- Arriola promised in a December 17, 2001 letter to return ₱437,000.00 on January 7, 2002 plus interest at 16% per annum from July 1, 2001, but reneged.
- Arriola issued checks (one dated June 20, 2002 and another on July 11, 2002) that were dishonored (closed account; insufficient funds).
- Del Rosario independently contacted Candelaria via Brisbane White Pages and learned from Candelaria that she neither was selling the property nor had authorized Arriola to sell it.
- Additional documentary exhibits included telephone records, the Brisbane White Pages (Exh. "Q"), and a Statutory Declaration of Cecilia Elicanal Villanueva certifying the White Pages copy.
Arriola’s Participation at Trial and Loss of His Testimony
- Arriola’s direct testimony was stricken off the record and his right to present evidence was deemed waived after he repeatedly failed to appear for cross‑examination.
- The record documents scheduled dates for his cross‑examination being postponed and Arriola’s absences: June 20, 2006 (presiding judge on leave), September 5, 2006 (accused indisposed due to illness), November 7, 2006 (accused failed to appear despite notice).
- The RTC warned Arriola that another failure to appear would justify striking his testimony; he failed to appear and did not complete cross‑examination.
RTC Ruling (April 17, 2007)
- RTC convicted Arriola of Estafa under Article 315, paragraph 2(a), finding the prosecution proved guilt beyond reasonable doubt.
- RTC findings emphasized fraudulent representations, Arriola’s admission of receipt of ₱437,000.00, and the accused’s failure to rebut prosecution evidence.
- RTC imposed an indeterminate penalty of four (4) years, two (2) months and one (1) day of prisión correccional (minimum) to twenty (20) years reclusion temporal (maximum), and ordered return of ₱437,000.00 to Del Rosario.
Post‑Judgment Payment and Appeal
- Arriola paid Del Rosario ₱437,000.00 on October 15, 2007.
- Arriola appealed to the Court of Appeals on June 11, 2008, arguing: conviction rested on hearsay; deprivation of due process; lack of deceit and that guilt was not proven beyond reasonable doubt; and no damage because the money had been returned.
Court of Appeals Ruling (August 5, 2011) and Resolution (January 3, 2012)
- CA denied Arriola’s appeal, affirming RTC’s finding that elements of Estafa by deceit were present.
- CA characterized Arriola’s representations (authority to sell, correspondences, authorization letter, fax, Deed) as fake.
- CA held Del Rosario’s testimony about the phone call to Candelaria was not pure hearsay because it was considered in conjunction with corroborative proof (telephone records, Brisbane White Pages, statutory declaration). The statements were treated as independently relevant (i.e., to prove that such statements were made).
- CA found Arriola had actively participated in RTC proceedings and had been warned of consequences for non‑appearance; thus, lack of due process claim failed.
- Because Arriola had paid the subject amount, CA deleted the portion of RTC decision ordering payment of ₱470,000.00 (noting modification to delete payment ordering).
- CA denied Arriola’s Motion for Reconsideration in its January 3, 2012 Resolution.
Issues Presented in the Petition to the Supreme Court
- Assignment of Errors raised by Arriola:
- CA erred in giving credence to hearsay evidence of the prosecution.
- CA erred in not finding good faith when Arriola attempted and actually paid the purchase price plus interest.
- CA er