Spouses Dulay v. People of the Philippines G.R. No. 215132, September 13, 2021, (Hernando, J.

Facts: Petitioners claimed ownership of a 450-square-meter parcel in Baguio City and sold it to private
complainants, the couples Isabelo and Hilaria Dulos (Hilaria; collectively as spouses Dulos); hence,
petitioners were charged with estafa under RPC Article 315 2(a).

Petitioners filed a Motion to Quash before the arraignment, which the RTC refused. The RTC ruled that:
(1) the trial court has jurisdiction to try the estafa matter under RFC Article 315 2(a), and (2) there is no
other pending criminal case before the first level courts of Agoo, La Union that constitutes litis pendentia.
As a result, petitioners pled not guilty during their arraignment.

The RTC found petitioners guilty of Estafa under Article 315, (2)(a) of the RPC. The trial court ruled that
all the elements of estafa by deceit under Article 315 (2)(a) of the RFC were established and proven by
the prosecution beyond reasonable doubt.

On appeal, the appellate court upheld the petitioners' conviction and expanded their responsibility for civil
damages to include interest payments. The lower courts all agreed that petitioners sold the subject
property to the Dulos spouses under false pretenses of ownership.

Issue: Whether petitioners are guilty of the crime of Estafa when private complainants were aware that
the subject property was not in their names at the time of the transaction.

Ruling: There is no merit in petitioners' appeal.

The lower courts determined that petitioners are not the owners, particularly the registered owners, of the
subject property. Nonetheless, they plainly sold the property to the Dulos couples, which they do not
possess under any circumstances. In fact, the vacillating justifications raised by the petitioners highlight
their deception.

First. Petitioners made false pretenses and fraudulent misrepresentations to complainants, the Dulos
spouses, which included the following false claims.

Second. The second, third, and fourth elements of the offense are also present, as determined by the
lower courts.

As demonstrated herein, petitioners committed estafa by deceit under Article 315 paragraph 2(a) of the
RPC.