G.R. Nos. 246265-66, March 15, 2021
MAYBELA. UMPA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Maybel Umpa, an employee of the Land Registration Authority (LRA), was consulted by private complainant Lory Malibiran in February 2010 on how to obtain the approved plan, tax declaration, and Certificate of Title for a 7.2-hectare property in Rodriguez, Rizal. Umpa assured Malibiran she could produce the documents and asked for a P20,000.00 research fee. She later introduced Malibiran to Carlito Castillo, also an LRA employee. In October 2010, Umpa informed Malibiran he needed to pay an additional P620,000.00 to facilitate the release of the documents. Malibiran gave the amount, but Umpa failed to deliver any document. Malibiran filed a complaint with the LRA, where Umpa and Castillo initially agreed to return the money but only Castillo appeared at a subsequent hearing. Malibiran later withdrew his LRA complaint and filed a complaint before the Office of the Ombudsman. After finding probable cause, two Informations were filed against Umpa and Castillo before the Regional Trial Court (RTC) of Quezon City for Estafa under Article 315(2)(a) of the Revised Penal Code and violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act). The case against Castillo was dismissed after Malibiran executed an Affidavit of Desistance in his favor. The RTC found Umpa guilty of both charges. On appeal, the Sandiganbayan affirmed the RTC’s decision but modified the penalty for estafa in light of the retroactive application of the more beneficial R.A. No. 10951 .

ISSUE

Whether the Sandiganbayan gravely erred in affirming the RTC’s Joint Decision finding petitioner Maybel Umpa guilty beyond reasonable doubt of Estafa under Article 315(2)(a) of the Revised Penal Code and violation of Section 3(e) of R.A. No. 3019 .

RULING

The Supreme Court DENIED the petition and AFFIRMED the Sandiganbayan Decision and Resolution. The Court held that all elements of both crimes were proven beyond reasonable doubt. For Estafa under Article 315(2)(a), the Court found that Umpa employed false pretenses or fraudulent acts by assuring Malibiran she could facilitate the issuance of the documents despite having no authority to do so, that Malibiran relied on these pretenses and was induced to deliver P640,000.00, and that Malibiran suffered damage due to Umpa’s failure to deliver. For violation of Section 3(e) of R.A. No. 3019 , the Court found that Umpa, a public officer, acted with manifest partiality, evident bad faith, or gross inexcusable negligence in misrepresenting her capacity to facilitate the documents, causing undue injury to Malibiran. The Court ruled that the alleged inconsistencies in Malibiran’s statements pertained to Castillo’s participation and did not affect Umpa’s culpability. The Sandiganbayan correctly applied R.A. No. 10951 retroactively, modifying the penalty for estafa to an indeterminate sentence of two months and one day of arresto mayor, as minimum, to one year and one day of prision correccional, as maximum. Umpa was also ordered to pay Malibiran P640,000.00 as actual damages.