G.R. No. 1650 - People vs. Litonjua

A check from a genuine check book, kept by a person identified as "Jean M. Poizat," was presented for collection.
The check bore what appeared to be a signature of Mr. Poizat, which was later determined to be a forgery.
The forged signature was so skillfully imitated that, despite minor variations in handwriting, it almost passed unnoticed during the rush of business, as testified by the assistant cashier, Mr. John Martin.

Along with the check, a note was found which requested sixty bank notes of fifteen dollars each—a denomination for which bank notes were not issued.
The note, like the check, raised suspicion because it sought to transact in non-issued currency denominations, thereby compounding the fraudulent character of the presentation.

Lino Litonjua, an employee of Mr. Poizat, was responsible for presenting the check and the accompanying note for payment at the Guaranty Trust Company office in Manila.
Upon notification by the bank regarding discrepancies in the signature, Mr. Poizat did not acknowledge the signature on the check or the note, indicating the absence of any legitimate consent.
Evidence gathered on Litonjua included:

A paper bearing an inverted tracing of Mr. Poizat’s signature.
A certificate of good conduct, which was seemingly issued and signed by Mr. Poizat in favor of Litonjua.
Additional documents found in Litonjua’s desk, such as the stub of the check used for payment and another note similar to the one used to request the bank notes.

The evidence against Cirilo Santiago primarily stemmed from the incriminating statement of his co-defendant, Litonjua.
Litonjua asserted that Santiago had given him the check, and noted that the handwriting and figure formations on the falsified check were similar to those on the stubs of checks previously written by Santiago.
Despite the alleged resemblance in handwriting between the authentic samples of Santiago and the forged documents, the evidence was deemed insufficient to conclusively attribute the forgery to him, particularly given the uncorroborated nature of Litonjua’s testimony.

Whether the evidence is sufficient to conclusively establish that the signature on the check was a forgery, particularly as it pertains to proving the commission of the offense by Lino Litonjua.
Whether the similarities in handwriting and figure formations between the authentic documents of Cirilo Santiago and the forged check provide reliable proof of his involvement in the forgery.
The credibility and admissibility of the co-defendant Litonjua’s incriminating statements against Cirilo Santiago, especially in the absence of independent corroboration.