G.R. No. 152335 December 19, 2005
Romeo G. Lorenzo, Petitioner, vs. The People of the Philippines, Respondent.

FACTS

Petitioner Romeo Lorenzo was charged with estafa under Article 315, paragraph 2(a) of the Revised Penal Code. The Information alleged that on or about January 14, 1993, in San Pedro, Laguna, Lorenzo, conspiring with his wife, defrauded Myrla Minggoy by falsely representing that he had lawful rights to a house and lot in Rosario Complex, which he offered to sell for ₱150,000.00. Minggoy, after inspecting the property and verifying Lorenzo’s Statement of Account with the GSIS showing arrears, paid the amount upon the execution of sale documents before a lawyer. Lorenzo, however, refused to vacate the property. Minggoy later discovered from the GSIS that the Deed of Conditional Sale in Lorenzo’s favor had already been cancelled in May 1991 for non-payment, a fact Lorenzo allegedly concealed.
Lorenzo presented a different version, claiming Minggoy was a real estate agent to whom he gave a Special Power of Attorney to sell the property. He asserted he signed documents in blank, relying on Minggoy’s assurances they were for prospective buyers, and only learned later the documents included a Deed of Absolute Sale and Waiver of Rights. He denied receiving the ₱150,000.00 and claimed no knowledge of the GSIS cancellation. The Regional Trial Court convicted Lorenzo, a decision affirmed by the Court of Appeals.

ISSUE

Whether the prosecution proved beyond reasonable doubt all elements of estafa through false pretenses or fraudulent acts under Article 315, paragraph 2(a) of the Revised Penal Code.

RULING

Yes. The Supreme Court affirmed the conviction. The elements of estafa under Article 315, paragraph 2(a) are: (1) the accused made false pretenses or fraudulent representations; (2) such pretenses or representations were made prior to or simultaneous with the commission of the fraud; (3) the accused had fraudulent intent; (4) the offended party relied on the false pretenses and was induced to part with money or property; and (5) the offended party suffered damage. The Court found all elements present. Lorenzo’s representation that he could legally transfer ownership of the property was false, as his right had been cancelled by the GSIS years prior. This representation was made before Minggoy parted with her money. Lorenzo’s fraudulent intent was evident from his concealment of the cancellation. Minggoy reasonably relied on this representation, especially after seeing the GSIS Statement of Account which did not on its face show cancellation, and she suffered damage by losing ₱150,000.00. The Court rejected Lorenzo’s defense, noting the detailed and consistent testimony of Minggoy and the documentary evidence, including the GSIS cancellation letter, which outweighed his bare denials. The factual findings of the lower courts, which found Minggoy’s version credible, are generally binding on appeal.