Case Digest (G.R. No. 220916) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Camilo Camenforte and Robert Lastrilla (G.R. No. 220916, June 14, 2021), Aurora and Rafael Granda sold multiple parcels of their Tacloban properties via three separate deeds of sale dated December 7, 1985. Two transactions involved the Uy siblings, the third involved Robert and Norma Lastrilla. Nearly fifteen years later, Rafael A. Granda, a grandson and heir, discovered these deeds had been annotated only in 2000 and alleged they were fraudulently antedated and bore forged signatures of his deceased grandparents. A PNP-Crime Laboratory report supported the forgery claim. Consequently, criminal informations for falsification were filed at RTC-Branch 8 against notary public Camilo Camenforte, Silvina Granda and Lastrilla. Meanwhile, other heirs, Benjamin Granda and Blanquita Serafica, filed Civil Case No. 2001-09-135 in RTC-Branch 9 seeking nullification of the same deeds on grounds of falsification. Branch 9 dismissed their complaint for lack of Case Digest (G.R. No. 220916) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioner: People of the Philippines, represented by the Office of the Solicitor General.
- Respondents: Camilo Camenforte (notary public) and Robert Lastrilla (vendee).
- Chronology and Transactions
- December 7, 1985 – Spouses Aurora and Rafael Granda executed three deeds of sale:
- First Deed (TCT Nos. T-249 & T-1312) sold to five Uy siblings for ₱3,800,000.00.
- Second Deed (TCT No. T-816) sold to six Uy vendees for ₱5,000,000.00.
- Third Deed (TCT No. T-6736) sold to Robert and Norma Lastrilla for ₱200,000.00.
- Circa 2000 – First two deeds were annotated and new titles issued; third TCT was nonexistent.
- Deaths: Rafael Granda in June 1989; Aurora Granda on September 16, 2000.
- Criminal Proceedings
- Early 2000 – Rafael A. Granda (grandson) filed complaint for falsification (Articles 171 & 172, RPC), alleging:
- Forged signatures of Aurora and Rafael.
- Antedated execution to December 7, 1985.
- PNP-Crime Laboratory report: signatures not genuine.
- RTC-Branch 8 charged Silvina Granda, Camenforte and Lastrilla with falsification in three separate informations.
- Respondents moved to dismiss on res judicata and prejudicial question grounds; RTC granted dismissal (Aug 20, 2009).
- Civil Proceedings
- August 21, 2001 – Benjamin R. Granda and Blanquita R. Serafica (heirs) filed Civil Case No. 2001-09-135 for nullification of titles and deeds with damages against the Uy siblings, Silvina and Lastrilla.
- June 6, 2005 – RTC-Branch 9 dismissed the complaint for lack of proof of forgery; held deeds genuine and duly notarized.
- Court of Appeals affirmed; judgment became final by October 26, 2007.
- Appeals and Petition
- Petitioner’s motions for reconsideration before RTC and CA denied.
- April 27, 2015 – CA denied petitioner’s appeal in CA-G.R. CEB-CR No. 01796.
- June 14, 2021 – Supreme Court granted review under Rule 45.
Issues:
- Res judicata
- Whether the final civil judgment in Civil Case No. 2001-09-135 bars the criminal prosecutions against respondents.
- Prejudicial question
- Whether the civil court’s final finding of genuineness of signatures constitutes a prejudicial question that precludes the criminal cases for falsification.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)