G.R. No. 34516 ; November 10, 1931
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. MELECIO A. REYES, defendant-appellant.

FACTS

The accused, Melecio A. Reyes, was employed as a timekeeper of the Calamba Sugar Estate. He was charged with the crime of “estafa through falsification of a private document.” The information alleged that during July 1929, in Calamba, Laguna, he willfully falsified the estate’s time book by making it appear that laborer Ciriaco Sario worked 21 days when Sario had actually worked only 11 days. By this falsification, the accused appropriated the sum of ten pesos to the damage and prejudice of the Calamba Sugar Estate. The trial court convicted him of the complex crime and sentenced him to prision correccional.

ISSUE

Whether the accused should be convicted of the complex crime of estafa through falsification of a private document, or simply of falsification of a private document under Article 304 of the Penal Code.

RULING

The Supreme Court modified the trial court’s judgment. It held that the accused’s act constituted the crime of falsification of a private document with prejudice to a third person, defined and penalized under Article 304 of the Penal Code, and not the complex crime of estafa through falsification. Following established doctrine, when an accused is charged with such acts, there are not two distinct crimes of estafa and falsification; thus, Article 89 of the Penal Code (on penalties for complex crimes) is not applicable. The Court sentenced the accused to one year, eight months, and twenty-one days of presidio correccional, a fine of 2,501 pesetas, and to indemnify the Calamba Sugar Estate in the amount of P10.

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