G.R. No. and Date: G.R. No. L-12822; February 11, 1918

FACTS:
An information was filed charging Ponciano Remigio, Feliciano Limjuco, Anselmo Abela, and Ramon Kamatoy with the complex crime of estafa through falsification of documents. The defendants allegedly conspired to defraud the Shanghai Life Insurance Company (Ltd.) by securing a life insurance policy (No. 14842) for P5,000 in the name of a fictitious person, Maria de Lima. They submitted falsified documents, including an application, medical certificates, a beneficiary’s claim, and a death certificate, falsely stating that Maria de Lima existed, was insured, and had died of typhoid fever, thereby fraudulently collecting P4,832 from the insurance company.

The defendants were granted separate trials. Ponciano Remigio was first tried, found guilty, and sentenced. The case against Feliciano Limjuco was dismissed to utilize him as a state witness. Appellant Anselmo Abela was subsequently tried, found guilty, and received a sentence identical to Remigio’s. Ramon Kamatoy was later tried and acquitted. Abela appealed his conviction, arguing that the acquittal of his alleged co-conspirator Kamatoy, particularly regarding the falsified death certificate (Exhibit D), undermined the evidence against him and rendered his conviction invalid.

ISSUE:
Whether the acquittal of alleged co-conspirator Ramon Kamatoy renders the evidence against appellant Anselmo Abela incompetent and necessitates Abela’s acquittal.

RULING:
No. The Supreme Court affirmed the conviction of Anselmo Abela, albeit with a modified penalty.

The Court held that the acquittal of one alleged conspirator does not, as a matter of law, bar the conviction of another. The conspiracy was proven as an evidentiary fact to establish the crime of estafa through falsification. The acts and declarations of a co-conspirator, even one subsequently acquitted, remain admissible against the others if the conspiracy itself is otherwise established by competent evidence. The guilt of each conspirator is individual and determined by their own participation.

The evidence, including the testimony of co-defendant turned state witness Feliciano Limjuco, sufficiently established Abela’s participation in the conspiracy. He, as a physician, provided a falsified medical certificate (Exhibit B) attesting to the health of the non-existent insured, which was essential to the fraudulent scheme. His guilt was not dependent on Kamatoy’s conviction for falsifying the death certificate.

The penalty was modified pursuant to Act No. 2712, which reduced the penalty for the crime. Considering the aggravating circumstance of abuse of confidence, the Court sentenced Anselmo Abela to six years of prision correccional, a fine of P2,000, indemnification of P4,832 to the Shanghai Life Insurance Company, and payment of costs.

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