G.R. No. 227069 - Lamsen vs. People

On September 30, 2003, an Information was filed before the Metropolitan Trial Court (MeTC) of Manila, charging petitioner Hilario Lamsen with falsification of public documents under Article 172(1) of the Revised Penal Code (RPC).
The falsified document was a Deed of Absolute Sale dated April 21, 1993, regarding a parcel of land in Barrio Malabo, Municipality of Valenzuela, Metro Manila, covered by Transfer Certificate of Title No. V-16641.
The deed purportedly showed that spouses Aniceta dela Cruz and Nestor Tandas sold the property to Lamsen for P150,000.00, with their forged signatures affixed without their knowledge or consent.

The subject property was registered under Aniceta dela Cruz’s name, married to Nestor Tandas.
On September 7, 2001, Aniceta died, leaving her nieces Teresita dela Cruz Lao and Carmelita Lao Lee as heirs.
Teresita, unable to find the original duplicate title, executed an affidavit of loss, which was annotated on the title at the Registry of Deeds (RD) of Valenzuela City on October 19, 2001.
Teresita and Carmelita executed an extrajudicial settlement of Aniceta’s estate.
Teresita’s petition for issuance of a second owner’s duplicate title was dismissed based on Lamsen’s opposition, who claimed possession of the original duplicate title.

On May 9, 2002, the RD informed Teresita by letter that a deed of sale involving the subject property was requested for registration.
The requesting party withdrew the papers, and Teresita obtained a photocopy of the deed from the Notarial Section of Manila, as the original was missing from the RD file.
Teresita submitted the photocopy to the Philippine National Police Crime Laboratory for examination, suspecting forgery of signatures of spouses Tandas.
Document Examiner II Alex Batiles testified that the signatures appeared dissimilar between questioned and standard samples, indicating forgery.

Lamsen denied the charges, asserting that he validly purchased the property from spouses Tandas in 1993, witnessed by Nicasio Cruz and Francisco Capinpin, notarized at GSIS Office, Manila.
He claimed to have taken the original deed and left a copy at the notary’s office but did not inform Aniceta’s relatives of the sale.
The MeTC found Lamsen guilty beyond reasonable doubt in its July 5, 2011 Decision, sentencing him to imprisonment and a fine, citing expert testimony on forgery and failure to prove genuineness of the signatures.

The Regional Trial Court (RTC) of Manila, Branch 34, affirmed the MeTC conviction in its March 28, 2012 Decision, rejecting Lamsen’s prescription argument and relying on expert testimony and circumstantial evidence including:

The Court of Appeals (CA) affirmed the RTC's ruling on January 30, 2015, upholding conviction based on these findings.
Despite motions for reconsideration, a manifestation and affidavit of desistance by heirs Teresita and Carmelita, and a motion for new trial, all reliefs were denied.
Lamsen filed the instant petition for review on certiorari before the Supreme Court.

Whether or not petitioner Hilario Lamsen’s conviction for falsification of public documents under Article 172(1) of the Revised Penal Code should be upheld.