Estafa by false pretenses etc., A315(2) Revised Penal Code

A315(2) estafa by means of false pretenses or fraudulent acts executed prior to or simultaneously with the commission of the fraud may be committed:

1) Article 315(2)(a): By using fictitious name, or falsely pretending to possess power, influence, qualifications, property, credit, agency, business or imaginary transactions, or by means of other similar deceits.

2) Article 315(2)(b): By altering the quality, fineness or weight of anything pertaining to his art or business.

3) Article 315(2)(c): By pretending to have bribed any Government employee, without prejudice to the action for calumny which the offended party may deem proper to bring against the offender. In this case, the offender shall be punished by the maximum period of the penalty.

4) Article 315(2)(d): By post-dating a check, or issuing a check in payment of an obligation when the offender therein were not sufficient to cover the amount of the check. The failure of the drawer of the check to deposit the amount necessary to cover his check within three (3) days from receipt of notice from the bank and/or the payee or holder that said check has been dishonored for lack of insufficiency of funds shall be prima facie evidence of deceit constituting false pretense or fraudulent act. (As amended by R.A. 4885, approved June 17, 1967.)

5) Article 315(2)(e): By obtaining any food, refreshment or accommodation at a hotel, inn, restaurant, boarding house, lodging house, or apartment house and the like without paying therefor, with intent to defraud the proprietor or manager thereof, or by obtaining credit at hotel, inn, restaurant, boarding house, lodging house, or apartment house by the use of any false pretense, or by abandoning or surreptitiously removing any part of his baggage from a hotel, inn, restaurant, boarding house, lodging house or apartment house after obtaining credit, food, refreshment or accommodation therein without paying for his food, refreshment or accommodation.

a. Article 315(2)(a): Fictitious name, false power, influence, qualifications, etc.

Article 315(2)(a): By using fictitious name, or falsely pretending to possess power, influence, qualifications, property, credit, agency, business or imaginary transactions, or by means of other similar deceits.

Elements of the offense of estafa by means of deceit under Article 315(2)(a):

1) That there must be a false pretense, fraudulent act or fraudulent means;

2) That such false pretense, fraudulent act or fraudulent means must be made or executed prior to or simultaneously with the commission of the fraud;

3) That the offended party must have relied on the false pretense, fraudulent act or fraudulent means, that is, he was induced to part with his money or property because of the false pretense, fraudulent act or fraudulent means; and

4) That as a result thereof, the offended party suffered damage. (Dulay III v. People, G.R. No. 215132, September 13, 2021, Per Hernando, J.)

1) Element 1: False pretense, fraudulent act or fraudulent means

For the first element, there must be a false pretense, fraudulent act or fraudulent means.

[“Fraud”] [is] the voluntary execution of a wrongful act, or a willful omission, knowing and intending the effects which naturally and necessarily arise from such act. or omission. In its general sense, fraud is deemed to comprise anything calculated to deceive, including all acts and omissions and concealment involving a breach oflegal or ethical duty, trust, or confidence justly reposed, resulting in damage to another, or by which an undue and unconscientious advantage is taken of another. Fraud is also described as embracing all multifarious means which human ingenuity can device, and which are resorted to by one individual to secure an advantage over another by false suggestions or by suppression of truth and includes all surprise, trick, cunning, dissembling, and any unfair way by which another is cheated. (Dulay III v. People, G.R. No. 215132, September 13, 2021)

[D]eceit [is] the false representation of a matter of fact whether by words or conduct, by false or misleading allegations, or by concealment of that which should have been disclosed which deceives or is intended to deceive another so that he shall act upon it to his legal injury. (Ibid.)

Yulo v. Gonzales, G.R. No. 239090, June 17, 2020, Per Inting, J.:

• The petitioners failed to sufficiently allege all of the foregoing elements in their Complaint-Affidavit. Their allegation that respondent Jaye induced them through fraudulent representations and false pretenses to invest their money is instantly belied by their own statement in their complaint, to wit:

1.4 We are formally charging the Respondents co-conspirators with 35 counts of Estafa by unfaithfulness and abuse of confidence as defined under Article 315 paragraph 1 (b) and 35 counts of Estafa by false pretenses as defined by paragraph 2 (a) of the same Article of the Revised Penal Code, to wit:

x x x x

2.2 We first heard about Respondent Jaye through a mutual friend [M.] Onate (“Ms. Onate”) when we asked her who her broker was. She identified her broker as Respondent Jaye who is the wife of Respondent Bienvenido, a very close friend of her brother. We asked for an introduction to Respondent Jaye.

• It must be noted that the petitioners were the ones who asked [M.] Onate (Onate) to be introduced to respondent Jaye and it was Onate who introduced respondent Jaye as her broker. Clearly, it was through the representation of Onate that petitioners will earn substantial amount of money in the stock market that induced them to invest their money. Verily, no deceit or fraud could be attributed to respondent Jaye as would induce the petitioners to part with their money or property.

2) Element 2: Made or executed prior to or simultaneously with the fraud

For the second element, such false pretense, fraudulent act or fraudulent means must be made or executed prior to or simultaneously with the commission of the fraud.

Arriola v. People, G.R. No. 199975, February 24, 2020, Per Hernando, J.:

• The deceit and false pretenses committed by Arriola prior to the transfer of money, laid out by Del Rosario in open court, are as follows:

• First, Arriola held himself out to Del Rosario as a duly authorized person to sell Candelaria’s lot and showed her a letter apparently signed by Candelaria to that effect. However, Candelaria’s alleged Authorization28 in favor of Arriola only stated [that the authority is to recover a certain amount of money].

• The Authorization contained no such authority in favor of Arriola to sell Candelaria’s lot. Assuming that the Authorization was genuine, its wordings gave Arriola nothing more than an authority to receive the payment for the supposed sale of Candelaria’s lot. There was no explicit mention of any sale to be facilitated by Arriola. Despite such a patently defective Authorization, Arriola still volunteered information to Del Rosario that he was also the broker of Candelaria’s lot and could negotiate the sale of the property.

• An authority to receive the payment cannot be impliedly construed as an authority to sell a piece of real property. Here, the Authorization was not in any way the special power of attorney contemplated and required by law. Being a real estate broker by profession, Arriola should be well-equipped with the basic knowledge on the technicalities in conveyances of real property for another person. This pretense can only be perceived as misleading, false, and fraudulent, as Arriola acted before Del Rosario as though there was an express grant of authority to sell Candelaria’s lot in his name, when in fact there was none.

• Second, Arriola also presented to Del Rosario a fax transmission allegedly from Candelaria addressed to him simultaneous to the full payment of the supposed purchase price.

• As with the semantics of the Authorization, the fax transmission was likewise bereft of any indication that Arriola, or anyone else, had been particularly entrusted with the sale of Candelaria’s property, other than the processing of its alleged documentation and the pertinent government transactions.

• Third, Arriola presented to Del Rosario a ready-made Deed of Absolute Sale with Candelaria’s signature already affixed thereto. Nothing else attested to the genuineness of this document aside from the compelling . assurances by Arriola to Del Rosario. These assurances having successfully blocked any doubt on the Deed of Absolute Sale, Del Rosario signed it on June 28, 2001 and Arriola had it notarized on August 2, 2001. It is curious, however, that while it is established that Candelaria resided in Australia, there was no indication or testimony that Candelaria was actually present in the Philippines to sign the Authorization or appear before the notary public for the notarization of the Deed of Absolute Sale.

• The differences between the signatures are too blatant to further require the assessment of a handwriting expert. The “P” at the beginning of the signature on the Authorization is boxy and seem to have. been drawn with a hesitant hand; slanting, triangular, and terminating beyond the intersection of the lower and upper loops in the fax transmission; and then rounded and surprisingly upright in the Deed of Absolute Sale. The “g” in the Authorization is small and slides to the lower loop without closing the upper loop; large, elongated, and indented upper loop before proceeding to the equally-large second loop in the fax transmission; full unindented first loop while still rounded and upright in the Deed of Absolute Sale. While the copy of the fax transmission appended in the records is too blurred to further make out the “Candelaria” in the signature thereon, the same parts in the Authorization and the Deed of Absolute Sale remain decipherable. A prima facie evaluation thereof, even by an untrained eye, reveals discrepancies that are too dubious to be simply ignored.

3) Element 3: Reliance on the false pretense, fraudulent act or fraudulent means

For the third element, the offended party must have relied on the false pretense, fraudulent act or fraudulent means, that is, he was induced to part with his money or property because of the false pretense, fraudulent act or fraudulent means

Time and again we have ruled that the one induced, who must be ignorant of the falsity of the representations, must have relied on the truth thereof and, as a consequence, sustained injury. (Dulay III v. People, G.R. No. 215132, September 13, 2021, Per Hernando, J.)

Montano v. People, G.R. No. 141980, December 7, 2001, Per De Leon, Jr., J.:

• The act of the [the Accused] of deliberately and fraudulently misrepresenting to the private complainants that Legarda Pine Home of which he is the general manager, is the owner of the subject lot in Baguio City on which townhouse units would be built and that he has the right and authority to offer for sale the proposed townhouse units, when in fact he has none, so that he could, as in fact he collected money as downpayment for two (2) townhouse units from the private complainants and his failure to return the amounts that he had collected from them despite several demands, and considering that the townhouse units were never constructed, constitute the crime of estafa as defined and penalized under Article 315, par. 2(a) of the Revised Penal Code.

People v. Urquico, G.R. No. 138910, July 20, 2022, Per Hernando, J.:

• The testimonies of the private complainants, coupled with the documentary and object evidence, demonstrated that accused-appellant, under the false pretense of being a legitimate overseas worker recruiter, fraudulently induced private complainants to part with their money as part of the supposed recruitment process. Given that none of the private complainants was deployed abroad as they were just being scammed, they clearly suffered damage.

4) Element 4: Damage

For the fourth element, the offended party suffered damage – resulting from the reliance on the false pretense, fraudulent act or fraudulent means.

Dulay III v. People, G.R. No. 215132, September 13, 2021, Per Hernando, J.:

• We abide by the uniform factual findings of the lower courts which establish [the Accused’s] commission of estafa by deceit through false pretenses and fraudulent misrepresentation.

• First. [The Accused] made false pretenses and fraudulent misrepresentations to complainants, the spouses Dulos, consisting of the following untruthful claims: (1) that they owned the subject property which they could sell, and consequently transfer title, to the buyers; (2) that they are processing the reconstitution of TCT No. T-2135, title to the subject property; (3) that they are the Isidro and Virginia Dulay, the registered owners of the property, mentioned in TCT No. T-2315; (4) that Virginia and Elena (Dulay) are one and the same person; (5) in the alternative to the third and fourth claims, that Isidro and Virginia Dulay’s title is defective since Maria, from whom Isidro and Virginia trace their registered title, revoked the donation of the subject property; and (6) that their predecessor-in-interest to the property, Maria, is the adoptive mother of petitioner Isidro Dulay who therefore validly succeeds to the property.

• Here, [the Accused] employed a scheme of dissembling against the spouses Dulos by withholding from the latter the true registered owners of the subject property under TCT No. T-2135. [The Accused] took advantage of the demise of the real registered owners, the spouses Isidro and Virginia Dulay and more importantly, the similarity in the names of the two Isidros who are related and share the exact same name, i.e., Isidro Dulay.

• [The Accused’s] deceit is illustrated by their inconsistent and conflicting claims (a) that title to the subject property is simply being reconstituted to reflect their names, (b) that they are the same persons as Isidro and Virginia Dulay, and (c) that petitioner Isidro is a putative heir of Maria, the purported registered owner of the subject property prior to the registered owners reflected in TCT No. T-2135.

• On the whole, [the Accused] falsely pretended to the spouses Dulos that they owned the subject property and dissembled a supposed transfer or reconstitution of title thereto. [The Accused] simply did not own the subject property, not as registered owners or under any claim of title. Clearly, the first element of the offense, i.e. existence of false pretense, is present.

• Second. As found by the lower courts, the second, third and fourth elements of the offense are likewise present.

• [The Accused’s] false pretense of ownership which could transfer valid title to the subject property, was committed prior to and simultaneous with the commission of the fraud. Private complainants’ reliance on this false pretense induced and impelled them to purchase the subject property from sham owners who do not hold any color of title and pay them the total amount of P707,000.00.

• Plainly, [the Accused] deceived private complainants and misrepresented to them that: (a) TCT No. T-2135 covering the subject property is registered in their names; (b) the Virginia indicated in TCT No. T-2135 is the same person as petitioner Elena; and (c) they are simply reconstituting their lost title, TCT No. T-2135.

Artates v. People, G.R. No. 235724, March 11, 2020, Per Peralta, J.:

• [T]he Court affirms the findings of the courts below as to the presence of all the elements of the crime charged herein. As the appellate court ruled, the acts of [the Accused] of deliberately misrepresenting herself to the Pablicos as having the capacity to facilitate Jun’s entry into the police force through her husband so that she could, as she did, collect money from them allegedly for medical examination, service firearm, and other so-called requirements and her failure to return the same clearly amount to estafa by means of deceit.16 Contrary to the claims of [the Accused], the prosecution sufficiently established, through the following pertinent testimony of Patrocinia, the elements that Patrocinia was specifically induced by [the Accused]’s false pretense to part with her money, thereby suffering damage as a result thereo.

b. Article 315(2)(b): Alteration of quality, fineness, or weight

The elements of estafa through alteration under Article 315(2)(b):

1) That there is an art or business; and

2) That the offender alters the quality, fineness or weight of anything pertaining to his/her art or business. (REVISED PENAL CODE, Article 315(2)(b))

1) Element 1: Art or Business

For the first element, there is an art or business.

The art may refer to any form, such as drawing, painting, sculpting, and analogous thereto.

On the other hand, the business may be any type, such as online or brick-and-mortar, as well as in any industry.

2) Element 2: Alters quality, fineness or weight

For the second element, the offender alters the quality, fineness or weight of anything pertaining to his/her art or business.

c. Article 315(2)(c): Pretense of bribing Government employee

The elements of estafa through pretense of bribing a Government employee under Article 315(2)(c):

1) That there is a Government employee; and

2) That the offender pretended to another to have bribed said Government employee.

1) Element 1: Government employee

For the first element, there is a Government employee.

Government employee includes both public officials/officers and employees.

2) Element 2: Pretense of bribery

For the second element, the offender pretended to another to have bribed said Government employee.

There need not have been an actual bribery to have been committed. The mere fact that the offender pretended to have bribed a Government employee is sufficient to be held criminally liable.

d. Article 315(2)(d): Issuance of post-dated check without sufficient funds

Article 315(2)(d): By post-dating a check, or issuing a check in payment of an obligation when the offender therein were not sufficient to cover the amount of the check. The failure of the drawer of the check to deposit the amount necessary to cover his check within three (3) days from receipt of notice from the bank and/or the payee or holder that said check has been dishonored for lack of insufficiency of funds shall be prima facie evidence of deceit constituting false pretense or fraudulent act. (As amended by R.A. 4885, approved June 17, 1967.)

Elements of the offense of estafa by means of issuing a post-dated check without sufficient funds under Article 315(2)(a):

1) The offender has postdated or issued a check in payment of an obligation contracted at the time of the postdating or issuance;

2) At the time of postdating or issuance of said check, the offender has no funds in the bank, or the funds deposited are not sufficient to cover the amount of the check; and

3) The payee has been defrauded. (People v. Villanueva, G.R. No. 163662, February 25, 2015, Per Bersamin, J.)

The deceit should be the efficient cause of the defraudation, and should either be prior to, or simultaneous with, the act of the fraud. (Ibid.)

People v. Villanueva, G.R. No. 163662, February 25, 2015, Per Bersamin, J.:

• All the elements of estafa were present. The first element was admitted by [the Accused], who confirmed that she had issued the checks to Madarang in exchange for the jewelry she had purchased. There is no question that Madarang accepted the checks upon the assurance of [the Accused] that they would be funded upon presentment. It is clear that Madarang would not have parted with and entrusted the pieces of valuable jewelry to [the Accused] whom she barely knew unless [the Accused] gave such assurance to her. The second element was likewise established because the checks were dishonored upon presentment due to insufficiency of funds or because the account was already closed. The third element was also proved by the showing that Madarang suffered prejudice by her failure to collect from [the Accused] the balance of ₱995,000.00.

• In her defense, [the Accused] adverts to an agreement with Madarang whereby the latter would deposit or encash the checks only after being informed of the sufficiency of funds in [the Accused]’s account. [the Accused] posits that the receipt the Prosecution presented in evidence did not embody such agreement.

• This defense of [the Accused] is actually anchored on the rule that estafa will not lie when the parties waive the negotiable character of the check, and instead treat the same as proof of an obligation. For instance, when there is an agreement between the parties at the time of the issuance and postdating of the checks that the obligee shall not encash or present the same to the bank, the obligor cannot be prosecuted for estafa because the element of deceit is lacking. When the payee was informed that the checks are not covered by adequate funds, bad faith or estafa shall not arise.

• [The Accused] does not impress. Her defense crumbles because she did not present proof of the supposed agreement. The receipt signed by her proved the transaction and her issuance of the postdated checks by listing the items bought and the postdated checks issued as payment. If the parties really agreed for Madarang to deposit the checks only after notice of the sufficiency of funds, then such agreement should have been incorporated in the receipt as an integral part of the transaction, or simply written in another document with Madarang’s express conformity for [the Accused]’s protection. We simply cannot accept that [the Accused] signed the receipt despite not including the supposed agreement that would shield her from probable criminal prosecution. In that regard, her being a businesswoman presumably made her aware of the consequences of issuing unfunded checks. All that she is claiming here is that the receipt did not express the true intention of the parties, implying that no written document substantiated her alleged defense. She did not claim at all that she had been coerced or intimidated into signing the receipt as written. Her self-serving statements on the agreement were entirely inadequate to establish her assertions, for they were not proof.

a) Element 1: Post-dated check

For the first element, the offender has postdated or issued a check in payment of an obligation contracted at the time of the postdating or issuance.

1) The offender has postdated or issued a check in payment of an obligation contracted at the time of the postdating or issuance;

Is there deceit and damage when a bad check is issued in payment of a pre-existing obligation? It is clear that under the law, the false pretense or fraudulent act must be executed prior to or simultaneously with the commission of the fraud. To defraud is to deprive some right, interest, or property by deceitful device. In the issuance of a check as payment for a pre-existing debt, the drawer derives no material benefit in return as its consideration had long been delivered to him before the check was issued. In short, the issuance of the check was not a means to obtain a valuable consideration from the payee. Deceit, to constitute estafa should be the efficient cause of the defraudation. Since an obligation has already been contracted, it cannot be said that the payee parted with his property or that the drawer has obtained something of value as a result of the postdating or issuance of the bad check in payment of a pre-existing obligation. (People v. Tugban, G.R. No. 76212, April 26, 1991, Per Medialdea, J.)

Evidently, the law penalizes the issuance of a check only if it were itself the immediate consideration for the reciprocal receipt of benefits. In other words, the check must be issued concurrently with, and in exchange for, a material gain to make it a punishable offense under Article 315, paragraph 2(d) of the Revised Penal Code. In the issuance of a check to pay a pre-existing obligation, as in the instant case, the drawer derives no such contemporary gain in return since the obligation sought to be settled is already incurred and outstanding before the check is issued. (Castro v. Mendoza, G.R. No. 50173, September 21, 1993, Per Vitug, J.)

b) Element 2: No sufficient fund

For the second element, at the time of postdating or issuance of said check, the offender has no funds in the bank, or the funds deposited are not sufficient to cover the amount of the check.

People v. Montaner, G.R. No. 184053, August 31, 2011, Per Leonardo-De Castro, J.:

• The elements of estafa under paragraph 2(d), Article 315 of the Revised Penal Code are: (1) the postdating or issuance of a check in payment of an obligation contracted at the time the check was issued; (2) lack of sufficiency of funds to cover the check; and (3) damage to the payee.

• In the case at bar, the prosecution sufficiently established [the Accused]’s guilt beyond reasonable doubt for estafa under paragraph 2(d), Article 315 of the Revised Penal Code. According to Solis’s clear and categorical testimony, [the Accused] issued to him the 10 postdated Prudential Bank checks, each in the amount of ₱5,000.00 or a total of ₱50,000.00, in his house in exchange for their cash equivalent.

• From the circumstances narrated above, it was evident that Solis would not have given ₱50,000.00 cash to [the Accused] had it not been for her issuance of the 10 Prudential Bank checks. These postdated checks were undoubtedly issued by [the Accused] to induce Solis to part with his cash. However, when Solis attempted to encash them, they were all dishonored by the bank because the account was already closed.

• Solis wrote [the Accused] a demand letter dated October 13, 199611 which was received by [the Accused]’s husband to inform [the Accused] that her postdated checks had bounced and that she must settle her obligation or else face legal action from Solis. [The Accused] did not comply with the demand nor did she deposit the amount necessary to cover the checks within three days from receipt of notice. This gave rise to a prima facie evidence of deceit, which is an element of the crime of estafa, constituting false pretense or fraudulent act as stated in the second sentence of paragraph 2(d), Article 315 of the Revised Penal Code.

c) Element 3: Damage

For the third element, the payee has been defrauded. Meaning, the offender caused damage to the payee.

Damage and deceit are essential elements of the offense and must be established with satisfactory proof to warrant conviction, while the false pretense or fraudulent act must be committed prior to, or simultaneous with, the issuance of the bad check. The drawer of the dishonored check is given three days from receipt of the notice of dishonor to cover the amount of the check, otherwise, a prima facie presumption of deceit arises. (People v. Juliano, G.R. No. 134120, January 17, 2005, Per Azcuna, J.)

e. Article 315(2)(e): Defrauding proprietor/manager of hotel, inn, restaurant, etc.

Article 315(2)(e): By obtaining any food, refreshment or accommodation at a hotel, inn, restaurant, boarding house, lodging house, or apartment house and the like without paying therefor, with intent to defraud the proprietor or manager thereof, or by obtaining credit at hotel, inn, restaurant, boarding house, lodging house, or apartment house by the use of any false pretense, or by abandoning or surreptitiously removing any part of his baggage from a hotel, inn, restaurant, boarding house, lodging house or apartment house after obtaining credit, food, refreshment or accommodation therein without paying for his food, refreshment or accommodation.

The elements of estafa through defrauding a proprietor or manager under Article 315(2)(e):

1) 1^st mode

The elements are:

1) That the offender obtained any food, refreshment or accommodation at a hotel, inn, restaurant, boarding house, lodging house, or apartment house;

2) Without paying therefor; and

3) With intent to defraud the proprietor or manager thereof. (REVISED PENAL CODE, Article 315(2)(e))

a) Element 1: Food, refreshment, or accommodation

For the first element, the offender obtained any food, refreshment or accommodation at a hotel, inn, restaurant, boarding house, lodging house, or apartment house.

Article 315(2)(e) specifically identified three (3) things that the offender availed of and eventually did not pay, namely:

1) Food

2) Refreshment; and

3) Accommodation.

Thus, if an offender availed of services such as a massage – which is neither food, refreshment, nor accommodation, it may be argued that no crime is committed under this Article 315(2)(e). After all, criminal laws are interpreted strictly against the State and in favor of the accused.

b) Element 2: Non-payment

For the second element, the offender did not pay. Instead of settling the bill, the offender left such establishments without paying for the food, refreshment, or accommodation.

c) Element 3: Intent to defraud

For the third element, the offender intended to defraud the proprietor or manager thereof. The intent to defraud is crucial as a person who may simply forget to pay the bill. In such a case, there was no criminal intent on the part of the customer.

On the other hand, it is different if the person from the start intended to defraud the proprietor or manager of the establishment. Such criminal act/behavior is the one sought to be punished by the law.

b) 2^nd mode

The elements are:

1) That the offender obtained credit at hotel, inn, restaurant, boarding house, lodging house, or apartment house; and

2) By the use of any false pretense; and

3) Without paying for his food, refreshment or accommodation. (REVISED PENAL CODE, Article 315(2)(e))

1) Element 1: Obtained credit

For the first element, the offender obtained credit at hotel, inn, restaurant, boarding house, lodging house, or apartment house.

Credit means “the provision of money, good, or services with the expectation of future payment.” (Merriam-Webster Online Dictionary)

In other words, the offender opened a credit tab (bale or lista).

2) Element 2: False pretense

For the second element, the offender obtained credit by the use of any false pretense. This include any and all forms of deceit or fraudulent machinations, such as misrepresentation as to his/her identity, introduction as another person or identity theft, presenting false documents, and analogous thereto.

3) Element 3: Non-payment

For the third element, the offender did not pay for his/her food, refreshment or accommodation.

NB: Similar comment earlier that the offense is limited to non-payment of: food, refreshment or accommodation.

c) 3^rd mode

The elements are:

1) The offender abandons or surreptitiously removes any part of his baggage from a hotel, inn, restaurant, boarding house, lodging house or apartment house after obtaining credit, food, refreshment or accommodation therein; and

2) Without paying for his food, refreshment or accommodation. (REVISED PENAL CODE, Article 315(2)(e))

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