Batulanon V People

Batulanon v.
People
September 15, 2006
GR No. 139857
502 SCRA 35
Snares-Santiago, J.:
RELEVANT LAWS: ART. 48 Penalty for complex crime- When a single

act constitutes two or more grave or less grave felonies, or when an
offense is a necessary means for committing the other, the penalty for
the most serious crime shall be imposed, the same to be applied in its
maximum period.
Article 172 (2) of the RPC elements of falsification of private

document are: (1) that the offender committed any of the acts of
falsification, except those in paragraph 7, Article 171; (2) that the
falsification was committed in any private document; and (3) that the
falsification caused damage to a third party or at least the falsification
was committed with intent to cause such damage.
FACTS: Leonila Batulanon was the manager-cashier of Polomok Credit

Cooperative Incorporated from May 1980 to December 22, 1982. She
was in charge of receiving deposits from and releasing loans to the
member of the cooperative. During an audit conducted in December
1982, certain irregularities concerning the release of loans were
discovered. Thereafter, four pieces of information for estafa thru
falsification of commercial documents were filed against Batulanon.
The petitioner pleaded not guilty to the charges, thereafter a joint trial
on the merits ensued. The prosecution presented Maria Theresa
Medallo, Benedicto Gopio, Jr., and Bonifacio Jayoma as witnesses.
Medallo, the posting clerk whose job was to assist Batulanon in the
preparation of cash vouchers testified that on certain dates in 1982,
Batulanon released four Cash Vouchers representing varying amounts
to four different individuals as follows: On June 2, 1982, Cash Voucher
No. 30A for P4,160.00 was released to Erlinda Omadlao; on September
24, 1982, Cash Voucher No. 237A for P4,000.00 was released to
Gonafreda Oracion; P3, 500.00 thru Cash Voucher No. 276A was
released to Ferlyn Arroyo on October 16, 1982, and on December 7,
1982, P5,000.00 was released to Dennis Batulanon thru Cash Voucher
No. 374A.
She testified that Omadlao, Oracion, and Dennis Batulanon were not
eligible to apply for the loan because they were not bona fide members
of the cooperative. Arroyo, on the other hand, was a member of the
cooperative, but subsequently withdrew her membership. Moreover
there was no proof that she applied for a loan with PCCI in 1982.
Furthermore she categorically stated that she saw Batulanon sign the
names of Oracion and Arroyo in their respective cash vouchers and
made it appear in the records that they were payees and recipients of
the amount stated therein and as to the signature of Omadlao in Cash
Voucher No. 30A, she declared that the same was actually the
handwriting of the appellant. Gopio corroborated Medallo's testimony
that Omadlao, Arroyo, Oracion and Dennis Batulanon are not members
of PCCI. Jayoma testified that the loans made to Oracion, Omadlao,
Arroyo and Dennis Batulanon did not pass through the cooperative's
Credit Committee and PCCI's Board of Directors for screening
purposes. He claimed that Oracion's signature on Cash Voucher No.
237A is Batulanon's handwriting, he also testified that among the four
loans taken, only that in Arroyo's name was settled.
ISSUE: Whether there is a complex crime of estafa through falsification

of private document
HELD: there is no complex crime of estafa through falsification of

private document, it is important to ascertain whether the offender is
to be charged with falsification of a private document or with estafa. If
the falsification of a private document is committed as a means to
commit estafa, the proper crime to be charged is falsification. If the
estafa can be committed without the necessity of falsifying a
document, the proper crime to be charged is estafa.
Thus, in People v. Reyes, the accused made it appear in the time book
of the Calamba Sugar Estate that a laborer, Ciriaco Sario, worked 21
days during the month of July, 1929, when in reality he had worked
only 11 days, and then charged the offended party, the Calamba Sugar
Estate, the wages of the laborer for 21 days. The accused
misappropriated the wages during which the laborer did not work for
which he was convicted of falsification of private document.
In U.S. v. Infante,the accused changed the description of the pawned
article on the face of the pawn ticket and made it appear that the
article is of greatly superior value, and thereafter pawned the falsified
ticket in another pawnshop for an amount largely in excess of the true
value of the article pawned. He was found guilty of falsification of a
private document.
In U.S. v. Chan Tiao,the accused presented a document of guaranty
purportedly signed by Ortigas Hermanos for the payment of P2,055.00
as the value of 150 sacks of sugar, and by means of said falsified
documents, succeeded in obtaining the sacks of sugar, was held guilty
of falsification of a private document.
the Court of Appeals correctly held Batulanon guilty beyond

reasonable doubt of Falsification of Private Documents in Criminal
Case Nos. 3625, 3626 and 3453. However, in Criminal Case No. 3627,
the crime committed by Batulanon is estafa and not falsification.

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Batulanon v.

RELEVANT LAWS: ART. 48 Penalty for complex crime- When a single

Article 172 (2) of the RPC elements of falsification of private

FACTS: Leonila Batulanon was the manager-cashier of Polomok Credit

ISSUE: Whether there is a complex crime of estafa through falsification

HELD: there is no complex crime of estafa through falsification of

the Court of Appeals correctly held Batulanon guilty beyond

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