Title
De Castro vs. People
Case
G.R. No. 171672
Decision Date
Feb 2, 2015
Bank teller convicted of estafa and falsification for forging depositors' signatures, withdrawing funds; SC upheld conviction, modified penalties under Article 48 RPC.

Case Digest (G.R. No. 196383)
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)

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