SAMSON V CA

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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.

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