G.R. No. 179448 - Tanenggee vs. People

Parties and Procedural History
Carlos L. Tanenggee (petitioner) was charged in five separate Informations dated March 27, 1998 before the RTC of Manila, Branch 30 (Criminal Case Nos. 98-163806 to 98-163810) with estafa through falsification of commercial documents.
The five Informations allege identical modus operandi but differ in check/note numbers, dates and amounts.

Factual Allegations
Between July 24 and December 22, 1997, petitioner, as Branch Manager of Metrobank Commercio Branch, allegedly prepared and filled up Metrobank promissory notes and cashier’s checks in the name of Romeo Tan for loans totaling over ₱43 million.
He is said to have counterfeited Tan’s signature, forged endorsements, and obtained proceeds amounting to ₱15,362,666.67 (first loan) and similar sums in four other transactions, which he then misappropriated.

Pre-Trial and Trial Proceedings
Cases were consolidated. No stipulations were made except on identity, jurisdiction and petitioner’s position. Prosecution marked exhibits A–L.
Prosecution witnesses included:

A Metrobank Internal Affairs officer who secured petitioner’s written statement;
An assistant branch manager who testified signatures were forged;
An NBI handwriting expert; and
A Loans Clerk who delivered and saw petitioner receive the proceeds.

Defense Version
Petitioner admitted managing the branch since 1994 and handling high-value client Romeo Tan with a ₱40 million line of credit.
He claimed Tan used a fictitious “Jose Tan” account for security, personally signed all notes and checks via messenger, and only the July 24, 1997 loan involved Tan’s personal visit.
Petitioner alleged his January 1998 written statement was extracted under duress during an administrative inquiry without counsel.

Decisions Below
RTC Decision (June 25, 1999): Found guilt beyond reasonable doubt on all five counts; imposed indeterminate sentences of 8 years prision mayor (minimum) to 20 years reclusion temporal (maximum) consecutively, plus indemnities with 18% interest.
CA Decision (December 12, 2006): Affirmed with modification—ordered interest on one loan from July 24, 1997; denied Motion for Reconsideration on September 6, 2007.
Petitioner filed a Petition for Review under Rule 45 raising two basic issues.

Whether the CA erred in admitting petitioner’s written statement on the ground that it was not obtained during custodial interrogation.
Whether the prosecution established all essential elements of estafa through falsification of commercial documents.