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INTESTATE ESTATE OF MANOLITA GONZALES VDA. DE CARUNGCONG v. PEOPLE

FACTS:

In this case, a complaint-affidavit for estafa was filed against William Sato by Mediatrix Carungcong, alleging that Sato fraudulently obtained the signature and thumbmark of their blind mother on a Special Power of Attorney, which authorized the sale of four valuable pieces of land. Sato found buyers for the properties and made one of his daughters sign three deeds of absolute sale. However, the proceeds from the sale were not accounted for or delivered to their mother.

Sato was accused of estafa under Article 315, paragraph 3(a) of the Revised Penal Code. He was alleged to have induced the blind and elderly mother to sign the special power of attorney, making her believe it was related to her taxes. Sato then made his daughter sign three Deeds of Absolute Sale and misappropriated and converted the proceeds to his own use. Despite demands for an accounting and delivery of the proceeds, Sato refused to comply. The complaint was initially dismissed, but on appeal, the Secretary of Justice directed the filing of an Information against Sato. Sato moved for the quashal of the Information, citing the exempting circumstance under Article 332 of the Revised Penal Code. The trial court granted Sato's motion and ordered the dismissal of the case.

The petitioner, the intestate estate of Manolita, represented by Mediatrix, filed a petition for certiorari in the Court of Appeals to reverse the trial court's rulings. The Court of Appeals dismissed the petition, upholding the application of the exempting circumstance under Article 332 in favor of Sato. The main issue in the case is the effect of death on the relationship by affinity created between a surviving spouse and the blood relatives of the deceased spouse. The interpretation of Article 332 and its coverage in exempting certain individuals from criminal liability for theft, estafa, or malicious mischief is crucial in resolving the case. It should also be noted that the issue of whether the relationship by affinity is dissolved upon the death of one spouse is a new issue in Philippine jurisprudence, which lacks guidance from previous cases or commentaries.

ISSUES:

  1. For purposes of Article 332 of the Revised Penal Code, is the relationship by affinity created between the husband and the blood relatives of his wife (as well as between the wife and the blood relatives of her husband) dissolved by the death of one spouse, thus ending the marriage which created such relationship by affinity?

  2. Does the beneficial application of Article 332 cover the complex crime of estafa through falsification?

RULING:

  1. The relationship by affinity created between the surviving spouse and the blood relatives of the deceased spouse survives the death of either party to the marriage which created the affinity. This principle applies to the justifying circumstance of defense of one's relatives under Article 11 of the Revised Penal Code, the mitigating circumstance of immediate vindication of grave offense committed against one's relatives under Article 13 of the same Code, and the absolutory cause of relationship in favor of accessories under Article 20 of the same Code.

  2. The absolutory cause under Article 332 of the Revised Penal Code only applies to the simple crimes of theft, swindling, and malicious mischief. It does not apply where any of the crimes mentioned under Article 332 is complexed with another crime, such as theft through falsification or estafa through falsification. Therefore, Sato cannot avail himself of the absolutory cause for the complex crime of estafa through falsification of public documents.

PRINCIPLES:

  1. Continuing Relationship by Affinity Relationship by affinity between a surviving spouse and the blood relatives of the deceased spouse remains even after the death of the spouse. (Article 11, Article 13, and Article 20 of the Revised Penal Code)

  2. Absolutory Causes and Complex Crimes Absolutory causes under Article 332 of the Revised Penal Code apply strictly to simple crimes and not to complex crimes.

  3. Interpretation of Penal Laws Penal laws are strictly construed against the state and liberally in favor of the accused. (In dubio pro reo)

  4. Rule of Lenity When faced with two possible interpretations of a penal statute, the interpretation which is more lenient to the accused should be adopted.

  5. Formal Plurality of Crimes In a complex crime, while involving multiple acts, there is single criminal intent resulting in one criminal liability. (Article 48 of the Revised Penal Code)