G.R. No. L‑5283
January 15, 1910

FACTS
– The United States (plaintiff‑appellee) convicted Tomas Umali (defendant‑appellant) of estafa for obtaining ₱101 under false pretenses in the sale of land parcels.
– The trial court found the amount obtained to be ₱87.40; the Supreme Court corrected this to ₱101.
– While the case was on appeal, Umali filed an affidavit seeking a new trial to introduce the testimony of two witnesses (Joaquin Garcia Lopez and Municipal President Pastor Espinosa) who allegedly would attest that the lands were sold at ₱50 per hectare and that the proceeds were immediately paid to the accused.
– Umali claimed the witnesses were not called because his counsel, in error, advised that the prosecution’s evidence was “of no effect.”

ISSUE
Whether the failure to present the said witnesses, allegedly due to counsel’s mistake, constitutes a valid ground for granting a new trial and overturning the conviction for estafa.

RULING
– The Court held that mistakes or negligence of counsel are not grounds for a new trial; a defendant is bound by the conduct of his attorneys. (Citing De Florez v. Raynolds and Darbey v. State.)
– Although the witnesses’ testimony was available, the Court found no indication that their evidence, if offered, would have materially altered the result. Their statements conflicted with existing evidence and, even if true, would only show the estafa benefitted a third partynot absolve the accused.
– The factual findings of the trial court regarding the deceitful inducement of the landowners and the concealment of the higher price received were affirmed.
– The amount obtained under false pretenses is corrected to ₱101, and the conviction, sentence, and costs are affirmed.

Disposition: Conviction and sentence of the trial court affirmed; motion for a new trial denied.

Concurrence: Chief Justice Arellano and Justices Torres, Mapa, Johnson, and Moreland.