G.R. No. L-10364 - Samson vs. Court of Appeals

Rufino T. Samson, along with co-defendants Amado L. Cruz, Bonifacio Vergara, and others, was charged in two separate informations before the Court of First Instance of Manila with the complex crime of estafa through falsification of checks issued by the Philippine National Bank.
In the trial, all were found guilty. While co-defendants received penalties ranging from six years and 1 day up to nine years, 4 months and 1 day of prision mayor plus fines and cost orders, Samson’s conviction was modified on appeal to a lesser offense of committing the crime “through gross imprudence,” for which he was sentenced to 4 months of arresto mayor in each case.

The case originated when Amado L. Cruz sought the assistance of Samson on October 2, 1948, to obtain checks purportedly belonging to legitimate claimants, namely Rosalina Paras and Espiridion Lascano.

Cruz’s representations led Samson to assist by identifying the claimants checking their residence certificates and accompanying them to request Lt. Manuel Valencia serve as guarantor.
Lt. Valencia, relying on the assurances from Samson, accompanied the group to the Deceased Check Delivery Section of the AFP’s Finance office.

At the Bureau of Treasury, Samson again assisted by signing as a witness on the back of Rosalina’s check and, notably, signing as the last indorser on Espiridion’s check.
The checks were subsequently delivered to Samson and Cruz, who then counted and distributed the funds.
Following the cashed check, the party had lunch at a restaurant where Vergara contributed a small sum of money and additionally paid Samson a token amount (P10 for taxi fare and P300 as part of the arrangement for other officers’ assistance).

On October 4, 1948, while still at Camp Murphy, Samson was informed by a companion (Severino Anda) that the checks had been cashed by impersonators and the funds delivered to the wrong parties.
Concerned about the possibility of fraud, Samson:

Traveled to Sorsogon on October 5 and 6 to locate the real claimants.
Investigated by observing an old couple he suspected to be the imposters and reported the incident to the local police—having their fingerprints, names, and address taken.

Samson later reported his findings on October 8 to Sgt. Luis Balignasan at G-2 PC, submitting copies of the suspects’ fingerprints as corroborative evidence.

The Court of Appeals found that Samson had performed his acts without confirming, by all proper means, the identity of the real claimants.
His reliance on assurance from his former classmate, Cruz, and the presentation of residence certificates (which are not conclusive means of identification) was held to be insufficient precaution given the significant amount involved (over P12,000).
Despite the absence of malicious intent or personal gain (as shown by the relatively meager token payment of P310), his failure to exercise proper caution amounted to gross negligence or reckless imprudence.

Whether the acts performed by Samson, particularly his failure to independently verify the identity of the claimants, constituted gross imprudence sufficient to render him criminally liable.
Whether the offense of estafa through falsification can, under the evidence presented, be sustained on a charge of criminal negligence even when the information alleged a willful act.
Whether the court erred in denying Samson’s motion for a new trial, especially in light of newly presented evidence and the variance between the offense charged (willful falsification) and the offense proven (falsification by negligence).