G.R. No. 36139 ; October 8, 1932
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. VICENTE ORENDAIN and MARIA OLARTE, defendants-appellants.

FACTS

Defendants Vicente Orendain (a notary public) and Maria Olarte (daughter of Raymunda Toribio) were convicted of estafa through falsification of a public document. The conviction stemmed from deeds of sale, prepared and notarized by Orendain, wherein Raymunda Toribio and her husband conveyed several parcels of land to Olarte for a nominal consideration of P1. Raymunda, an elderly woman, claimed she was told the documents were powers of attorney (poderes), not deeds of sale (ventas). The prosecution relied on this claim to establish fraud. However, evidence showed Raymunda had a prior intent to deprive her husband of any interest in her property upon her death and wanted to place the lots under her daughter’s control.

ISSUE

Whether the defendants are guilty beyond reasonable doubt of the crime of estafa through falsification of a public document.

RULING

No. The Supreme Court reversed the conviction and acquitted the defendants. The Court found grave doubt as to their guilt. The evidence indicated Raymunda Toribio’s clear desire to transfer control of her property to her daughter, which the deeds accomplished. The nominal consideration of P1 was facially inadequate for a fraudulent sale, suggesting no intent to conceal a true sale. The testimony of Raymunda was deemed unreliable. Furthermore, the inconsistent outcomes in three related cases based on virtually identical facts and documents reinforced the doubt. The defendants were acquitted with costs de oficio.

AI Generated by Armztrong.