Case Digest (G.R. No. 196383) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Marieta de Castro vs. People of the Philippines (G.R. No. 171672, February 2, 2015), the petitioner, a teller at BPI Family Savings Bank’s Malibay branch in Pasay City, was charged with four counts of estafa through falsification of a commercial document for forging withdrawal slips in October and November 1993. Depositors Amparo Matuguina and Milagrosa Cornejo had left their passbooks with de Castro, who then prepared and signed withdrawal slips bearing counterfeit signatures enabling her to withdraw ₱65,000.00 from Matuguina’s account and ₱2,000.00 from Cornejo’s account. Branch manager Cynthia Zialcita uncovered the forgeries upon reconciling the account records, and internal inquiry revealed de Castro’s initials on the falsified slips. Confronted by Zialcita and the depositors, de Castro admitted her misconduct and executed several confession statements during the bank’s administrative investigation. On July 13, 1998, the Regional Trial Court of Pasay City found her guilt Case Digest (G.R. No. 196383) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedent Events
- Petitioner Marieta de Castro, a teller at BPI Family Savings Bank, Malibay Branch, forged signatures of depositors Amparo Matuguina and Milagrosa Cornejo on withdrawal slips in October–November 1993, enabling her to withdraw ₱65,000.00 from Matuguina’s account and ₱2,000.00 from Cornejo’s account.
- Depositors left their passbooks with petitioner; three disputed withdrawal slips (dated October 19, 29 and November 4) bore signatures unlike depositors’ specimens but bore petitioner’s initials. Teller Juanita Ebora processed the November 4 transaction believing petitioner had verified the signature.
- Discovery and Confession
- Branch Manager Cynthia Zialcita, suspecting irregularities, instructed assistant manager Benjamin Misa to visit Matuguina and Cornejo. Both denied signing the contested slips; petitioner then admitted she retained Matuguina’s passbook and had forged signatures.
- During an administrative investigation by bank superiors, petitioner initially denied, then confessed in writing (Exhibits K–O), provided a diary listing victim accounts, and was subsequently terminated. The bank reimbursed Matuguina; Cornejo recovered her funds from petitioner directly.
- Trial and Appeals
- RTC Pasay City (July 13, 1998) convicted petitioner of four counts of estafa through falsification of commercial documents, imposing indeterminate sentences in each case and ordering restitution.
- CA (August 18, 2005) affirmed the convictions, deleting only the ₱2,000 restitution for case 94-5525 as already paid.
- Petitioner elevated the case to the Supreme Court, raising constitutional and penalty-related issues.
Issues:
- Whether petitioner’s rights against self-incrimination, to due process, and to counsel were violated during her administrative investigation.
- Whether evidence obtained through the bank’s internal probe is inadmissible as the fruit of an unconstitutional procedure.
- Whether the penalties imposed comply with Article 48, Revised Penal Code, for complex crimes (estafa through falsification).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)