G.R. No. 127327 February 13, 2009
Liberata Ambito, Basilio Ambito, and Crisanto Ambito, Petitioners, vs. People of the Philippines and Court of Appeals, Respondents.

FACTS

Petitioners Liberata Ambito and Basilio Ambito were the principal owners of the Community Rural Bank of Leon, Inc. and the Rural Bank of Banate, Inc. in Iloilo, and owners of Casette Enterprises, which supplied farm implements to the banks’ loan borrowers. They purchased machineries and spare parts from Pacific Star, Inc. On several occasions in 1979, Basilio Ambito issued Manila Banking Corporation checks as down payments, which were later dishonored for insufficiency of funds. Simultaneously, Liberata Ambito obtained blank certificates of time deposit from the cashiers of their banks, Marilyn Traje of Rural Bank of Banate and Reynaldo Baron of Community Rural Bank of Leon, by pressuring them, assuring responsibility, and leveraging their positions as owners and superiors. These blank certificates were then filled up to name Pacific Star, Inc. as depositor and used as down payments for their purchases. Crisanto Ambito, brother of Basilio and manager of the Community Rural Bank of Leon, also pressured cashier Reynaldo Baron to sign and give blank certificates of time deposit. When Baron asked for duplicates, he was told the transaction was still being negotiated and later cancelled, and he was instructed to have similar blank certificates printed. Baron eventually resigned and reported the anomalies to Central Bank investigators.

ISSUE

The primary issues involve the criminal liability of the petitioners for: (1) multiple violations of Batas Pambansa Blg. 22 (Bouncing Checks Law) by Basilio Ambito; (2) multiple charges of the complex crime of Estafa through Falsification of Commercial Documents by Liberata and Basilio Ambito; and (3) two charges of Falsification of Commercial Document by Crisanto Ambito.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that all elements of the crimes were proven beyond reasonable doubt. For the violations of B.P. Blg. 22, Basilio Ambito issued checks that were subsequently dishonored for insufficiency of funds, and he was notified of the dishonor but failed to make good the amounts. For the complex crime of Estafa through Falsification of Commercial Documents, the petitioners, in conspiracy, falsified certificates of time deposit by making them appear that Pacific Star, Inc. made deposits when it did not, and used these falsified documents to defraud Pacific Star, Inc. by making it appear that down payments were made, thereby inducing it to deliver the purchased farm implements. The falsification was a necessary means to commit the estafa. For the charges of Falsification of Commercial Document against Crisanto Ambito, he, as a private individual, participated in the falsification of the certificates of time deposit, which are commercial documents, by causing the bank cashier to sign them in blank under circumstances constituting falsification. The defenses of good faith and lack of criminal intent were rejected, as the acts of obtaining blank certificates, filling them up without actual deposits, and using them as payment were indicative of fraudulent intent.