G.R. No. 150910 - Gonzaludo vs. People

Ulysses Villaflor, before his death in 1992, was a member of the Bacolod City Police Office.
On January 11, 1978, Ulysses married Anita Manlangit in Bacolod City, and the couple initially resided with Ulysses’s mother, Anastacia Tobongbanua, in Purok 5, Mansungay, Bacolod City.
Ulysses was later assigned to Pagadian City but frequently returned to Bacolod City to supervise his tire-recapping business.
Anita, his legal wife, secured a teaching job in Catubig, Samar, prompting her relocation, while Ulysses eventually returned to Bacolod City.
In December 1978, Ulysses purchased a small house for ₱1,500.00 near his mother’s residence.
In 1985, Ulysses took Rosemarie Gelogo as his mistress and brought her into the house.
Significant improvements were introduced in March 1991 that transformed the modest dwelling into a two-storey structure partially of concrete hollow blocks with galvanized iron roofing, enhancing its value to ₱200,000.00.

After Ulysses’s demise in January 1992, Rosemarie Gelogo offered the two-storey house for sale at the cheap price of ₱80,000.00.
Bienvenido Gonzaludo (also known as Ben Gonzaludo), the petitioner, initially showed no interest due to having an existing house and insufficient funds.
Petitioner later convinced spouses Gregg Canlas and Melba Canlas (to whom he was related by affinity) to buy the property.
On January 20, 1993, Rosemarie Gelogo and Gregg Canlas executed a Deed of Sale—witnessed by petitioner—where Rosemarie signed as “Rosemarie G. Villaflor,” representing herself as the lawful owner, thereby transferring all rights and interest in the house to Gregg Canlas.

An Information was filed on May 31, 1994, by private complainant Anita Manlangit (widow of Ulysses) charging Rosemarie Gelogo (alias Rosemarie Villaflor), the Canlas spouses, and petitioner with the crime of Estafa through Falsification of Public Document.
The allegation stated that on January 20, 1993, by using the fictitious surname “Villaflor,” Rosemarie misrepresented herself as Ulysses’s wife and lawful owner of the house, causing the Canlas spouses to buy the property for ₱80,000.00.
Although Rosemarie remained at large, the Canlas spouses and petitioner were arraigned and pleaded “Not Guilty.”
On February 17, 1998, the trial court acquitted the Canlas spouses but convicted petitioner for the complex crime of Estafa through Falsification of Public Document.

Petitioner was found guilty as a principal and co-conspirator.
He was sentenced, under Article 315 of the Revised Penal Code, to suffer an indeterminate penalty ranging from 8 years of Prision Mayor to 20 years of Reclusion Temporal.
Additionally, petitioner was ordered to pay ₱200,000.00 (value of the house) plus ₱20,000.00 as attorney’s fees.

Petitioner appealed the trial court’s conviction in the Court of Appeals (CA-G.R. CR No. 22185).
The appellate court, in its decision dated July 19, 2001, dismissed petitioner’s appeal for lack of merit and affirmed the trial court’s judgment.
A subsequent motion for reconsideration was denied by the appellate court in its resolution dated October 22, 2001.
Petitioner brought the present petition for review on certiorari challenging multiple points:

The assertion that the statutory elements of estafa through falsification of public document were not all present or proved.
The contention that material allegations lacked proof beyond a reasonable doubt.
The charge that the crime was either not properly charged or that the facts were misappreciated—specifically concerning the property’s status (conjugal property vs. property substantially belonging to Rosemarie Gelogo).
The argument that even if Rosemarie’s fraud could be established, the lack of inducement of the offended party (Anita Manlangit) to part with her property negated the efficient cause needed for an estafa conviction.

Whether all the statutory elements for the complex crime of Estafa through Falsification of Public Document, as charged under Article 315, paragraph 2(a) of the Revised Penal Code, were present and proved beyond a reasonable doubt.

Specifically, whether the false pretense or fraudulent representation by Rosemarie Gelogo—using the fictitious surname “Villaflor”—constituted the efficient cause that induced the offended party, Anita Manlangit, to part with her property.
Whether the act of fraud, committed by Rosemarie on behalf of the conspiracy with petitioner, sufficiently established the required element of inducement.

Whether petitioner, as a co-conspirator in the commission of the complex crime, could be convicted of estafa if one of the essential elements (the efficient cause of fraud leading to the parting with property) was absent.
Whether the disjointed nature of the complex crime allows for separate conviction of the offense of falsification of public document despite the failure to establish the estafa component.
The proper interpretation and application of prior jurisprudence concerning fraudulent misrepresentation as the primary cause for the victim’s loss.