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# AK055613
Intestate Estate of Manolita Gonzales Vda. De Carungcong vs. People, et al.
The Supreme Court ruled that the relationship by affinity between a surviving spouse and the blood relatives of the deceased spouse continues after death, but the absolutory cause under Article 332 of the Revised Penal Code does not apply to the complex crime of estafa through falsification of public documents.

Primary Holding

The Court reversed lower court rulings, holding that while affinity survives death, William Sato was not exempt from criminal liability for the complex crime of estafa through falsification.

Background

Mediatrix Carungcong, administratrix of her mother Manolita’s estate, accused her brother-in-law William Sato of estafa for fraudulently inducing Manolita (blind and elderly) to sign a falsified Special Power of Attorney (SPA) to sell her properties. Lower courts dismissed the case based on Article 332’s exemption for relatives by affinity.

History

  • 1995: Mediatrix appointed administratrix of Manolita’s estate.

  • 1996: Filed estafa complaint against Sato (I.S. No. 96-19651).

  • 1997: Quezon City Prosecutor dismissed the complaint.

  • 2000: Secretary of Justice reversed dismissal; Information filed in RTC.

  • 2006: RTC granted Sato’s motion to quash based on Article 332.

  • 2007: Court of Appeals affirmed RTC’s dismissal.

  • 2010: Supreme Court reversed and remanded the case.

Facts

  • 1. Sato allegedly deceived his blind mother-in-law, Manolita, into signing an SPA under false pretenses (claiming it related to taxes). This allowed Sato’s daughter to sell three Tagaytay properties. Sato misappropriated ₱22M in proceeds instead of remitting them to the estate.

Arguments of the Petitioners

  • 1. Zenaida (Sato’s wife and Manolita’s daughter) predeceased Manolita, terminating the affinity relationship.
  • 2. Article 332 does not apply to complex crimes like estafa through falsification.

Arguments of the Respondents

  • 1. Affinity survives Zenaida’s death, maintaining Sato’s exemption under Article 332.
  • 2. The State’s interest in family harmony aligns with exempting Sato from criminal liability.

Issues

  • 1. Does death dissolve the relationship by affinity under Article 332 of the RPC?
  • 2. Does Article 332 apply to the complex crime of estafa through falsification?

Ruling

  • 1. Affinity persists after death to uphold family harmony (adopting the “continuing affinity view”).
  • 2. Article 332 applies only to simple theft, estafa, or malicious mischief, not complex crimes. The falsification of public documents negated Sato’s exemption.

Doctrines

  • 1. Continuing Affinity: Affinity survives death to preserve family solidarity.
  • 2. Strict Construction of Penal Laws: Ambiguities favor the accused (Article 332’s exemption is strictly limited).
  • 3. In Dubio Pro Reo: Doubts resolved in favor of the accused (applied to affinity’s scope).
  • 4. Complex Crimes: Component crimes (e.g., falsification as a means for estafa) remove Article 332’s application.

Key Excerpts

  • 1. “The purpose of Article 332 is to preserve family harmony and obviate scandal.”
  • 2. “Falsification of a public document ... raises the presumption that Sato ... was the author thereof.”

Precedents Cited

  • 1. People v. Cristobal (1949): Applied Article 332 to exempt a son who stole from his mother.
  • 2. Gonzaludo v. People (2006): Established elements of estafa through falsification.
  • 3. People v. Salvilla (1989): Defined “necessary means” in complex crimes.

Statutory and Constitutional Provisions

  • 1. Article 332, Revised Penal Code: Exempts relatives by affinity from criminal liability for theft, estafa, or malicious mischief.
  • 2. Article 48, Revised Penal Code: Defines complex crimes.
  • 3. Constitution, Article II (Section 12) and Article XV (Section 1): State policy to protect family solidarity.