GR 171672; (February, 2015) (Digest)
G.R. No. 171672 February 2, 2015
MARIETA DE CASTRO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
The petitioner, Marieta de Castro, was a bank teller at BPI Family Savings Bank in Malibay, Pasay City. She was convicted for four counts of estafa through falsification of a commercial document. The charges stemmed from her forging the signatures of depositors Amparo Matuguina and Milagrosa Cornejo on withdrawal slips in October and November 1993, enabling her to withdraw a total of ₱65,000 from Matuguina’s account and ₱2,000 from Cornejo’s account. The scheme was discovered when the branch manager investigated after Matuguina reported issues with her passbook. The petitioner admitted to signing the withdrawal slips with fake signatures and executed confession letters during the bank’s internal administrative investigation. The Regional Trial Court (RTC) convicted her and imposed indeterminate penalties for each count. The Court of Appeals (CA) affirmed the RTC’s judgment but deleted the order for restitution of ₱2,000 in one case as it had already been paid to Cornejo. The petitioner appealed to the Supreme Court, contending her constitutional rights against self-incrimination, to due process, and to counsel were violated, rendering the evidence against her inadmissible.
ISSUE
Whether the petitioner’s constitutional rights against self-incrimination, to due process, and to counsel were violated during the bank’s internal investigation, thereby invalidating her conviction.
RULING
The Supreme Court denied the appeal and affirmed the CA decision with modifications to the penalties. The Court held that the constitutional rights against self-incrimination and to counsel invoked by the petitioner apply only in the context of custodial investigation by law enforcement agents for a criminal offense. The investigation conducted by the bank was an administrative inquiry by her superiors, not a custodial interrogation by the police. The petitioner was not coerced; she broke down and confessed when confronted by the depositors. The Court prescribed the correct penalties for the complex crime of estafa through falsification of commercial documents, following Article 48 of the Revised Penal Code, which requires imposing the penalty for the graver offense (falsification) in its maximum period. The penalties were modified accordingly. The Court also ordered the petitioner to pay BPI Family Savings Bank interest of 6% per annum on the aggregate amount of ₱65,000 from the finality of the judgment until full payment.