Case Digest (G.R. No. 153784)
Facts:
In PEOPLE OF THE PHILIPPINES v. Hon. Mariano C. Castaneda, Jr. and Benjamin F. Manaloto (177 Phil. 518, Feb. 27, 1979), the Private Respondent, Benjamin F. Manaloto, was charged before the Court of First Instance of Pampanga, Branch III, presided by Judge Mariano C. Castaneda, Jr., with Falsification of Public Document for forging his spouse’s signature. On or about May 19, 1975, in San Fernando, Pampanga, he executed a deed of sale purportedly conveying a house and lot belonging to their conjugal partnership to Ponciano Lacsamana (Doc. No. 1957, p. 72, Book LVII, Series of 1975) without his wife’s consent, having imitated her signature. The prosecution called the complainant-wife, Victoria Manaloto, as witness, but the defense successfully moved to disqualify her under Section 20(b), Rule 130 of the Revised Rules of Court, invoking the spousal testimony bar. The trial court granted the motion on March 31, 1977, and denied reconsideration on May 19, 1977. The Office of the ProviCase Digest (G.R. No. 153784)
Facts:
- Criminal Charge
- Victoria M. Manaloto, wife of Benjamin F. Manaloto, filed a complaint alleging that her husband, with deliberate intent to falsify, forged her signature on a deed of sale of a house and lot belonging to their conjugal partnership.
- The Information charged Benjamin F. Manaloto under Doc. No. 1957, Page No. 72, Book No. LVII, Series of 1975, notarized by Notary Public Abraham Pa. Gorospe, falsely representing that Victoria gave her marital consent to the sale in favor of Ponciano Lacsamana.
- Trial Court Proceedings and Petition for Certiorari
- At the Court of First Instance of Pampanga, the defense moved to disqualify the complainant-wife as a witness under Section 20(b), Rule 130 of the Revised Rules of Court. The prosecution invoked the exception for “a criminal case for a crime committed by one against the other.” The trial court granted disqualification in an order dated March 31, 1977, and denied reconsideration on May 19, 1977.
- The Office of the Provincial Fiscal filed a petition for certiorari in the Supreme Court to set aside those orders and obtained a Temporary Restraining Order on June 20, 1977. The Solicitor General appeared; memoranda were filed; and the case was submitted for decision.
Issues:
- Whether the falsification case against Benjamin F. Manaloto qualifies as a “criminal case for a crime committed by one spouse against the other,” thereby triggering the exception to the marital disqualification rule in Section 20(b), Rule 130 of the Revised Rules of Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)