G.R. No. 24099 - People vs. Diego An

The People of the Philippine Islands, as plaintiff and appellee, instituted criminal proceedings against the defendant, Diego An, for the crime of estafa through the falsification of a public document.
The case was decided by the Supreme Court, with the opinion penned by Justice Romualdez.

The defendant was originally convicted by the Court of First Instance of Marinduque and sentenced to ten years, eight months, and one day of prision mayor.
Additional penalties imposed included a fine of 250 pesetas; an order to indemnify the provincial government of Marinduque in the sum of P3; and subsidiary imprisonment in case of insolvency regarding the fine and indemnity.
The cost of the case was also borne by the defendant.

The crime charged—estafa by falsification—depended on the allegation that a public document (Exhibit A) was falsely executed to defraud.
The plaintiff contended that the document bore a statement (allegedly an amount of P3) that was untruthful, thereby constituting fraud.
However, evidence showed that the purported amount in Exhibit A was justly and duly paid by the defendant, as confirmed by uncontradicted testimony.

The only testimony supporting the alleged falsification came from Melecio Lagatoc, which was contradicted by the defendant and Cesar Marifosqui.
The testimony indicated that the P3.50 delivered by the defendant was divided with P0.50 for Lagatoc and the remainder in trust for Marifosqui, a fact suggestive of a legitimate transaction executed in good faith.
There was insufficient evidence to prove, beyond a reasonable doubt, the defendant’s evil intent in procuring Lagatoc’s signature on Exhibit A.

The decision refers to earlier cases, including United States vs. San Jose (7 Phil., 604) and United States vs. Arceo (17 Phil., 592), which established that once the presumption arising from the illegal act of falsification is overcome, a conviction cannot stand.

Whether the evidence presented was sufficient to establish the element of fraud or falsification necessary for a conviction of estafa.
Whether the testimony of Melecio Lagatoc, amidst contradictions by other witnesses, was adequate to prove criminal intent.

Whether the defendant’s act of delivering the P3.50, as well as the disbursement of funds to Lagatoc and Marifosqui as testified, constituted a good faith transaction.
Whether the absence of evidence demonstrating fraudulent motive negated the alleged falsification.

Whether the legal presumption arising from the alleged falsification was effectively overthrown by the uncontradicted evidence that the payment was properly executed.
Whether established jurisprudence supports the acquittal of the defendant under these circumstances.