Title
People vs Guzman
Case
G.R. No. 2424
Decision Date
Feb 17, 1906
A man accused of falsifying and passing counterfeit revenue stamps is acquitted due to insufficient evidence, including a confession that did not mention the stamps were counterfeit and the acquittal of other defendants charged with the same crime.
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Case Digest (G.R. No. 2424)

Facts:

  • The case The United States vs. Cosme Guzman et al. was decided on February 17, 1906, under G.R. No. 2424.
  • Dionisio Ceferino was the main defendant; Generoso Hernandez initially charged but later withdrew his appeal.
  • Ceferino faced accusations of falsifying and passing counterfeit revenue stamps.
  • Counterfeit stamps were discovered in various banks in Manila, including the Chartered Bank of India, Australia and China, the Guaranty Trust Company, and the International Banking Corporation.
  • There was no direct evidence linking Ceferino to the counterfeit stamps.
  • The prosecution relied on Ceferino's alleged written confession at a police station, where he claimed to have purchased $80 worth of stamps from Amado F. Roque and sold them to Exequiel A. Serrano.
  • Ceferino's confession did not explicitly state that the stamps were counterfeit.
  • Roque was also charged but acquitted; Serrano testified for the government and denied buying stamps from Ceferino.
  • No evidence connected Serrano to a separate incident involving counterfeit stamps from January 1904.
  • The trial court found Ceferino guilty, but he appealed due to insufficient evidence.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Dionisio Ceferino, reversing the lower court's judgment and sentence.
  • The Court determined that the evidence was insu...(Unlock)

Ratio:

  • The Court emphasized that a conviction must be based on sufficient evidence.
  • Ceferino's alleged confession was found inadequate as it did not clearly indicate that the stamps were counterfeit.
  • The acquittal of Roque and Serrano weakened the prosecution's case, as no direct link was established betw...continue reading

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