G.R. No. L-10364 and L-10376; March 31, 1958
RUFINO T. SAMSON, petitioner, vs. THE HONORABLE COURT OF APPEALS, ET AL., respondents.

FACTS

Rufino T. Samson was jointly charged with others for the complex crime of estafa through falsification of two checks of the Philippine National Bank. After trial, the Court of First Instance of Manila found them guilty. On appeal, the Court of Appeals affirmed the conviction but modified the penalty for Samson, finding him guilty of committing the crime through gross imprudence and sentencing him to 4 months of arresto mayor in each case. Samson filed a petition for review, contending that his acts do not constitute gross imprudence, that there is no such offense as estafa through falsification by negligence, and that the Court of Appeals erred in denying his motion for new trial.
The facts, as found by the Court of Appeals, are: Amado L. Cruz asked Samson for help in securing checks for claimants (supposedly the heirs of a deceased USAFFE lieutenant). Samson, relying on Cruz’s assurances and after examining residence certificates, accompanied the supposed claimants. He requested Lt. Manuel Valencia to act as guarantor, leading to the release of two checks. Samson then helped cash the checks at the Bureau of Treasury, signing as a witness for one check and as the last indorser for the other. He later accepted P310 from his co-accused. Two days later, upon learning the claimants were impostors, Samson went to Sorsogon, located the real claimants, confirmed the fraud, and reported the matter to the police and military authorities.

ISSUE

1. Whether the acts done by Samson constitute gross imprudence.
2. Whether there exists the offense of estafa through (falsification by) negligence.
3. Whether the Court of Appeals erred in denying his motion for new trial.

RULING

The Supreme Court found no error in the conclusion of the Court of Appeals. It held that Samson acted with gross negligence in assuring Lt. Valencia and the cashier of the identity of the supposed claimants without taking proper precautions, despite the large sum involved. His mere reliance on a former classmate’s assurance and residence certificates was insufficient, as these certificates are tax receipts, not reliable identification. The Court ruled that Samson cooperated in the commission of the complex offense of estafa through falsification by reckless imprudence by acts without which it could not have been accomplished, thus incurring liability. The penalty imposed was deemed appropriate. The Court also noted that the offense of falsification of a commercial document through reckless negligence exists, citing analogous cases. The denial of the motion for new trial was not erroneous.