G.R. No. L-6042, February 21, 1911
THE UNITED STATES vs. JOSE P. DE CASTRO and VICTOR V. ARAGON

FACTS

Accused Jose P. de Castro, together with Victor V. Aragon, was charged with estafa. De Castro, representing himself as “Pedro Narciso,” induced a clerk of W.F. Stevenson & Co. to advance P4,000 for a fictitious cargo of copra allegedly aboard the steamer Lucena. He presented a falsified bill of lading to support his representations. Aragon pleaded guilty at trial. De Castro admitted making the representations and participating in fabricating the bill of lading but claimed he acted in good faith, relying on Aragon’s story that the cargo belonged to Aragon’s uncles. The trial court convicted De Castro, sentencing him to presidio correccional and a fine, and ordered restitution.

ISSUE

Whether De Castro is guilty of estafa despite his defense of good faith and lack of criminal intent.

RULING

Yes. The Supreme Court affirmed the conviction. The evidence established that De Castro knowingly made false representations and used a falsified document to defraud W.F. Stevenson & Co. His claim of good faith was belied by his conduct: he failed to rectify the fraud upon discovery, spent part of the proceeds, and initially denied involvement when arrested. The court found that the transaction involved two crimesestafa and falsification of a private documentbut under Article 89 of the Penal Code, only the more serious offense (falsification) should be punished, with the penalty imposed in its maximum degree. The trial court’s sentence was within the legal limits.