G.R. No. 228739 - Bowden vs. Bowden

On January 19, 1979, an information for estafa through falsification of public documents was filed against Florentino T. Manuel in the Court of First Instance of Surigao del Sur, Criminal Case No. 850.
The information charged that during the period from March 2 to 15, 1974, petitioner, then employed as a Mining Engineer at the Regional Office of the Bureau of Mines in Surigao City, prepared and used falsified travel and daily time records.

The falsified documents (Itinerary of Travel and Daily Time Record) indicated that petitioner was on field work in various locations (Placer on March 2; Dinagat and Nonoc Island from March 7 to 10 and March 12 to 15, 1974), which was contrary to fact.
These falsified entries enabled petitioner to generate a general voucher to claim a per diem and daily allowance totaling P172.50, coupled with a nine-day salary of P172.17, aggregating to P344.67.
It is alleged that by making these false entries, petitioner willfully misappropriated, misapplied, and converted government funds to his own benefit.

The crimes charged were estafa (under Article 315, Revised Penal Code) through falsification of public documents (under Article 171, Revised Penal Code).
Petitioner’s alleged offense is noted as a complex crime where falsification serves as a means to commit estafa, thus implicating the imposition of the maximum period of penalty applicable to the more serious offense.

Although petitioner was ordered arrested on the same day and subsequently posted bail, several attempts to arraign him were unsuccessful.
Petitioner moved for the quashing and/or transfer of his case to the Sandiganbayan, invoking Section 4 of P.D. No. 1606, which confers original and exclusive jurisdiction on the Sandiganbayan over offenses committed by public officers that are punishable by a penalty higher than prision correccional.
The lower court denied his motion on August 7, 1979, maintaining the case within its jurisdiction, where it had first acquired jurisdiction.

Petitioner contended that because the penalty for falsification (punishable by prision mayor and a fine) exceeds prision correccional, the offense falls within the exclusive jurisdiction of the Sandiganbayan.
Respondents argued that since the estafa involving the amount of P344.67 is penalized with a minimum period of prision correccional under Article 315, the concurrent jurisdiction of the Court of First Instance is proper, given that it first acquired jurisdiction of the case.

Whether the Sandiganbayan has exclusive jurisdiction over the case pursuant to Section 4 of P.D. No. 1606, given that the underlying offense is punishable by a penalty higher than prision correccional.
Determination of which jurisdiction (Sandiganbayan or Court of First Instance) properly applies when the offense is complex in nature.

Whether the crime of estafa through falsification of public documents should be treated as a complex crime, thereby requiring the imposition of the maximum penalty prescribed by law.
How the dual elements of estafa and falsification interact in determining the applicable penalty and consequent jurisdiction.

The proper interpretation and application of Section 4 of P.D. No. 1606 in resolving jurisdictional disputes.
The reconciliation of the penalties provided under Articles 171 and 315 of the Revised Penal Code in assessing the correct jurisdiction.