"The courts below held Arriola criminally liable for Estafa by false deceits under Article 315, Paragraph 2(a) of the RPC, which provides:
Article 315. Swindling (estafa). -Any person who shall defraud another by any of the means mentioned hereinbelow x x x:
x x x x
2. By means of any of the following false pretenses or fraudulent acts executed prior to or simultaneously with the commission of the fraud:
(a) By using a fictitious name, or falsely pretending to possess power, influence, qualifications, property, credit, agency, business or transactions, or by means of other similar deceits.
Ordinarily, this Court desists from trifling with the findings of facts by the courts below. Findings by trial courts are generally accorded with great respect by the appellate courts, more so that the Supreme Court is not a trier of facts but of questions of law.
For this case, however, We defer to one of the prevailing exceptions listed by jurisprudence, that is, when the findings of fact by the trial court were conclusions without citation of specific evidence on which they are based.22 The courts below correctly convicted Arriola, but not much substantial discussion was made on the falsity of his representations and the documentary evidence thereof, which We now address.
The totality of circumstantial evidence sufficiently established Arriola's guilt for Estafa by means of deceit. "
G.R. No. 199975, February 24, 2020
LUIS T. ARRIOLA, PETITIONER, V. PEOPLE OF THE PHILIPPINES, RESPONDENT.
https://lawphil.net/judjuris/juri2020/feb2020/gr_199975_2020.html
