G.R. No. L-46306 - People vs. Castaneda, Jr.

Case Summary (G.R. No. L-46306)

Key Dates and Procedural Milestones (selected)

Alleged falsification: on or about May 19, 1975.
Lower court order disqualifying the wife as witness: March 31, 1977.
Denial of motion for reconsideration by the lower court: May 19, 1977.
Supreme Court action: temporary restraining order issued and Solicitor General required to appear on June 20, 1977; Solicitor General appearance filed June 27, 1977; memoranda filed August 30 and September 5, 1977; case submitted for decision thereafter.

Applicable Law and Constitutional Context

Primary rule invoked: Sec. 20, Rule 130 of the Revised Rules of Court (marital disqualification and its exceptions).
Controlling jurisprudential criteria: Ordono v. Daquigan, which adopts the rule from Cargill v. State that the exception applies when “an offense directly attacks, or directly and vitally impairs, the conjugal relation.” People v. Francisco was cited for related principles concerning identity of interests and the warranty of private confidences within marriage. Applicable constitution for legal context: the 1973 Philippine Constitution (decision rendered prior to the 1987 Constitution).

Procedural Posture

The Provincial Fiscal filed an information for falsification of a public document against Benjamin Manaloto after Victoria Manaloto lodged a complaint. At trial, the defense moved to disqualify Victoria from testifying under the marital witness-disqualification rule. The trial judge granted the disqualification and denied reconsideration. The People, through the Provincial Fiscal and later with the Solicitor General, filed a petition for certiorari with the Supreme Court seeking to set aside the orders disqualifying the wife and to enjoin further proceedings by the trial court pending resolution.

Facts Relevant to the Issue

The prosecution’s case rested on the allegation that the accused husband forged his wife’s signature on a deed of sale to make it appear she consented to the sale of conjugal property, when she had not consented. The falsification concerned a notarialized public document evidencing the sale of a conjugal asset. The complainant personally filed the complaint with the Provincial Fiscal and actively participated in the petition for relief before the Supreme Court, asserting that the marital relationship had deteriorated beyond repair.

Legal Issue Presented

Whether the falsification charge against the husband, based on the alleged forgery of his wife’s signature on a deed of sale of conjugal property, falls within the exception to marital witness disqualification in Sec. 20, Rule 130 — i.e., whether it is a “criminal case for a crime committed by one against the other” so that the wife may testify against the husband without her consent.

Governing Standard from Precedent

The Court applied the criterion articulated in Ordono v. Daquigan, adopting the rule from Cargill v. State: the marital witness-disqualification exception applies when an offense “directly attacks, or directly and vitally impairs, the conjugal relation.” The Court recognized that the test is neither as narrow as requiring a physical assault upon the spouse nor as broad as including every offense that may remotely affect domestic harmony; the offense must directly and vitally impair the conjugal relation. Ordono applied that standard to hold that certain crimes (e.g., a husband’s sexual assault upon his daughter) could be treated as crimes committed by the husband against the wife when they undermined the conjugal relationship.

Court’s Analysis Applying the Standard

The Court reasoned that the alleged forgery was a direct breach of the wife’s confidence and an act that directly and vitally impaired the conjugal relation. If the wife had consented in fact, no crime would exist; the gravamen of the offense is the husband’s unilateral and deceitful act against the wife's interest and the conjugal estate. The wife’s act of personally lodging the complaint

Case Syllabus (G.R. No. L-46306)

Title, Citation and Panel

Reported at 177 Phil. 518, Second Division, G.R. No. L-46306.
Decision date: February 27, 1979.
Authored by Justice SANTOS.
Concurrence by Fernando (Chairman), Barredo, Antonio, Aquino, and Concepcion, Jr.

Parties and Roles

Petitioner: People of the Philippines (Office of the Provincial Fiscal acting for the People).
Private respondent (accused in the criminal case): Benjamin F. Manaloto.
Witness / complainant: Victoria M. Manaloto (wife of accused).
Judicial respondent: Hon. Mariano C. Castaneda, Jr., Judge of the Court of First Instance of Pampanga, Branch III.
Solicitor General: required by the Court to appear as counsel for the petitioner and filed memorandum in support of the Petition.

Charge and Express Allegations in the Information

Criminal charge: Falsification of Public Document.
Alleged factual time and place: On or about the 19th day of May, 1975, in the Municipality of San Fernando, province of Pampanga, Philippines, within the jurisdiction of the Court of First Instance of Pampanga.
Specific allegation: The accused, Benjamin F. Manaloto, "with deliberate intent to commit falsification, did then and there willfully, unlawfully and feloniously counterfeit, imitate and forge the signature of his spouse Victoria M. Manaloto in a deed of sale executed by said accused wherein he sold a house and lot belonging to the conjugal partnership of said spouse in favor of Ponciano Lacsamana under Doc. No. 1957, Page No. 72, Book No. LVII, Series of 1975, notarized by Notary Public Abraham Pa. Gorospe, thereby making it appear that his spouse Victoria M. Manaloto gave her marital consent to said sale when in fact and in truth she did not."

Relevant Procedural History in Trial Court

Prosecution called complainant-wife, Victoria M. Manaloto, as witness at trial.
Defense moved to disqualify her from testifying, invoking Sec. 20, Rule 130 of the Revised Rules of Court (marital disqualification).
The text of Sec. 20 as quoted in the record: "SEC. 20. Disqualification by reason of interest or relationship . - The following persons cannot testify as to matters in which they are interested, directly or indirectly, as herein enumerated: xx xx xx xx xx (b) A husband can not be examined for or against his wife without her consent; nor a wife for or against her husband without his consent, except in a civil case by one against the other, or in a criminal case for a crime committed by one against the other."
The prosecution opposed the motion to disqualify, contending that the case falls under the exception "a criminal case for a crime committed by one against the other."
Respondent Judge, Hon. Mariano C. Castaneda, Jr., granted the motion and disqualified Victoria Manaloto from testifying for or against her husband by order dated March 31, 1977.
A motion for reconsideration was filed and denied by the respondent Judge in an order dated May 19, 1977.

Petition for Certiorari — Relief Sought and Intermediate Proceedings

The Office of the Provincial Fiscal filed this petition for certiorari on behalf of the People of the Philippines seeking to set aside the trial court orders disqualifying the wife and denying reconsideration.
Prayer included request for a preliminary injunction or temporary restraining order enjoining the judge from further proceeding with trial of Criminal Case No. 1011.
On June 20, 1977, the Supreme Court resolved to (a) issue a temporary restraining order, and (b) require the Solicitor General to appear as counsel for the petitioner.
The Solicitor General filed Notice of Appearance on June 27, 1977 and filed Memorandum in support of the Petition on August 30, 1977.
Respondents filed their Memorandum on September 5, 1977.
The case was thereafter considered submitted for decision.

Central Legal Issue Presented

Framed by the Court as the sole determinative issue: Whether the criminal case for Falsification of Public Document, filed against Benjamin F. Manaloto for allegedly forging his wife’s signature in a deed of sale so as to make it appear she consented to sale of conjugal property when she did not, "may be considered as a criminal case f