Rufino Samson helped secure and cash checks for two alleged claimants at the request of his former classmate Amado Cruz, but did not verify the claimants' identities. It was later discovered the checks were received and cashed by imposters. While Samson did not have criminal intent, the court found he acted with gross negligence in not ensuring the checks went to the real claimants. As a result, Samson was convicted of estafa through falsification of commercial documents due to his role in allowing the imposters to wrongfully obtain and cash the checks.
Rufino Samson helped secure and cash checks for two alleged claimants at the request of his former classmate Amado Cruz, but did not verify the claimants' identities. It was later discovered the checks were received and cashed by imposters. While Samson did not have criminal intent, the court found he acted with gross negligence in not ensuring the checks went to the real claimants. As a result, Samson was convicted of estafa through falsification of commercial documents due to his role in allowing the imposters to wrongfully obtain and cash the checks.
Rufino Samson helped secure and cash checks for two alleged claimants at the request of his former classmate Amado Cruz, but did not verify the claimants' identities. It was later discovered the checks were received and cashed by imposters. While Samson did not have criminal intent, the court found he acted with gross negligence in not ensuring the checks went to the real claimants. As a result, Samson was convicted of estafa through falsification of commercial documents due to his role in allowing the imposters to wrongfully obtain and cash the checks.
Rufino Samson helped secure and cash checks for two alleged claimants at the request of his former classmate Amado Cruz, but did not verify the claimants' identities. It was later discovered the checks were received and cashed by imposters. While Samson did not have criminal intent, the court found he acted with gross negligence in not ensuring the checks went to the real claimants. As a result, Samson was convicted of estafa through falsification of commercial documents due to his role in allowing the imposters to wrongfully obtain and cash the checks.
Download as DOCX, PDF, TXT or read online from Scribd
Download as docx, pdf, or txt
You are on page 1of 2
SAMSON v. COURT OF APPEALS, et al.
Saw a couple at the train station looking
G.R. Nos. L-10364 and L-10376 suspiciously at him, and Samson suspected Bautista Angelo, J. that they were talking about him. From there, he concluded that these must be the fake Petitioner: Rufino T. Samson claimants and reported this to the police. Respondents: Court of Appeals, et al. October 6 o Espiridion Lascaño was too old and FACTS weak to leave the house October 2, 1948 – Amado L. Cruz asked the o Rosalinda Paras was at school help of his former classmate, Rufino Samson where she was teaching. Did not (petitioner) to get the checks of two claimants receive check. at Camp Murphy. October 8 – Samson reported to Sgt. Luis Samson was assured by Cruz twice of the Balignasan, affidavit and suspect’s identity of the “claimants” and that he knew fingerprints were taken. them for a long time. Examined residence certificates attached to PROCEDURE claim papers. 1. Court of First Instance (Manila) Samson and Cruz went to Lt. Manuel a. Samson, jointly charged w/ Amado Valencia Cruz & Bonifacio Vergara + two o requested to act as guarantor others for the complex crime of o believed in the representation of Samson estafa through falsification of two and Cruz checks from PNB o went with them to the Deceased Check b. Pled not guilty Delivery Section c. Found guilty. Secured the release of ff checks: i. Penalty: 6yrs & 1day min.; 9yrs o Rosalina Paras (P6417.11) 4mos. & 1day prison mayor o Espiridion Lascaño (P6417.10) max. + Fine of P2500 & costs. Then, the three went to the Bureau of Idemnify cost of 2 checks equal Treasury, Finance building, to cash the to P5417.11 checks. 2. Court of Appeals Cashed by teller Rosario Mallari who knew a. Lower court decision stands Samson. b. Reduced penalty (Cruz + Vergara) Rosalina Paras did not know how to sign her c. Cruz charged only w/ estafa name so her thumbmark was on the back of through gross imprudence the check. i. Penalty: 4mos. arresto o Samson and Francisco Ordoñez signed mayor as witnesses below 3. Supreme Court Espiridion Lascaño signed at the back a. For review o Samson signed as last indorser Accounts delivered to Samson and Cruz ISSUES + HOLDING Francisco Ordoñez counted the money and 1. Whether or not Samson committed gross gave it to the claimants imprudence: Went to Aristocrat Retaurant Yes. Not willful, but negligent. No o P300 to officers for their help criminal intent, but failed to take o +P10 Samson’s taxi fare necessary steps to ensure that the checks are received by the actual claimants. given by Bonifacio Vergara Assurance from a former classmate is October 4 – Severino Anda told Samson that not enough to justify the disbursement. checks were delivered to wrong parties He must be wary of entrusting such an Samson left for Sorsogon to find real amount to people he’s never met before. claimants 2. Whether or not offense is estafa through falsification of checks by negligence: Yes. Impersonators managed to secure the checks and cash them through the actions of the appellant.
Article 17. RPC: Estafa through
falsification of commercial document. Samson committed estafa by failing to provide honest information that is essential to the security of said commercial document (PNB checks)
Rule 116. Section IV: “When there is
variance between the offense charged in the complaint or information, and that was proved or established by the evidence, and the offense as charged is included in or necessarily includes the offense proved, the defendant shall be convicted of the offense proved included in that which is charged or the offense charged included in that which is proved.” defendant Samson convicted of crime that is proved. Regardless of the mismatch between offense charged vs what actually happened, he will be convicted based on what is proven.
Section V: “Not all essential elements
of the offense charged in the information be proved. It is sufficient that some of said essential elements or ingredients thereof be established to constitute the crime proved.” The fact that the checks were wrongfully claimed and cashed through the negligent actions of the defendant Samson was enough to convict him.