G.R. No. 257 : August 29, 1902
THE UNITED STATES, complainant-appellant, vs. LINO REYES, defendant-appellee.

FACTS:
Flaviano Abreu and his wife were placed in possession of certain lands in Panducot and Mayto by a court order dated April 7, 1891, which was affirmed on April 17, 1893. They took possession on June 16, 1893. Prior to this, on May 1, 1893, Lino Reyes filed a petition for a state-granted title (composición) to a parcel of land in Mayto, Calumpit. He obtained the title deed, had it registered, and subsequently secured a court order for judicial possession. Abreu opposed this, leading the court to declare the proceedings contentious on June 16, 1894. Abreu, as private prosecutor, accused Reyes of the crimes of estafa (swindling) and falsification of a public document. He alleged that Reyes, through fraud and deceit, pretended to own the land in Panducot, obtained a title and possession to the prejudice of the Abreus, and made false statements in his petition to the state. Reyes claimed he sought the title for land he had possessed for over twenty years as guardian of his children, who inherited it from their grandmother.

ISSUE:
Whether the acts committed by Lino Reyes constitute the crimes of estafa and falsification of a public document.

RULING:
No. The Supreme Court affirmed the lower court’s judgment of acquittal. The facts do not constitute the crimes charged.
1. On the charge of estafa: The elements of deceit (dolo) and intent to gain (lucro causa) to the prejudice of another were not present. Reyes merely applied for a state title to land he claimed to have possessed for years. He did not, under a simulated claim, sell, lease, or encumber the land to defraud the Abreus. The core dispute was the ownership and identity of the lands (whether the Mayto land was the same as the Panducot land), which is a civil matter, not a criminal one.

The attachment on Reyes’s property was ordered lifted. Costs were adjudged de oficio.