G.R. No. 928 - People vs. Buenaventura

A check drawn in favor of "P. San Buenaventura" for $25 in gold was the subject of the controversy.
The check was indorsed by Francisco Buenaventura, who signed the indorsement using the name "P. San Buenaventura" instead of his own.

Francisco Buenaventura pleaded guilty to signing and collecting the check in the name of P. San Buenaventura.
In his confession, he explained that, on several occasions, his American employers mistakenly interchanged the initial “F” of his name with “P” and, noticing that the remainder of his surname coincided with that on the check, he indorsed it in good faith as his own.

The case involved the interpretation of section 1 of Article 300 of the Penal Code, which had been previously clarified in a series of decisions holding that no falsification occurs when there is no attempt to imitate, counterfeit, or simulate a signature.
Prior decisions cited by the court included cases such as United States vs. Paraiso and United States vs. Roque, establishing a line of precedent concerning the distinction between falsification and estafa.
The Government referenced three decisions of the Supreme Court of Spain (dated November 24, 1882; January 24, 1883; and January 31, 1884) that held a person is guilty of falsification when, by signing with another’s name, he falsely causes the document’s face to indicate participation of a non-signatory.

The trial court found the defendant guilty and imposed a sentence of eight years and one day of prision mayor along with a fine of 5,000 pesetas.
The case was re-examined on appeal and through cassation, with debates centering on whether the act fell within the ambit of falsification or constituted merely the crime of estafa.

Judge Torres argued that the act of substituting the signature—even without an overt attempt to imitate handwriting—simulated the participation of the true owner, thus constituting the crime of falsification.
He emphasized that the defendant’s actions, including signing with “P. Sn.” and the surname “Buenaventura” on the check that was intended for the real P. S. Buenaventura, inherently perverted the truth in a mercantile document.

Whether the deliberate substitution of the signature, without an attempt to imitate or counterfeit handwriting, should be charged as falsification of a mercantile document.
Whether this act, which rendered the document as apparently having been signed by the true owner, warrants criminal liability under the provisions governing falsification.

The proper classification of the crime: does the defendant’s conduct fall under falsification (as argued in the dissent) or should it be characterized as estafa, given the absence of a counterfeit attempt?
Whether the mistaken belief or confusion over the initials “F” and “P” can affect the element of malice and intent to defraud inherent in the offense charged.

How should the established doctrines (from both local case law and Spanish jurisprudence) be applied to determine if the act constitutes a crime of falsification or, alternatively, estafa?
Whether the distinction between private, public, and mercantile documents influences the classification of the crime in this instance.