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G.R. No. 150910: Gonzaludo vs. People

The case G.R. No. 150910 involves Bienvenido Gonzaludo, accused of estafa through falsification of a public document related to a house owned by Ulysses Villaflor. The Supreme Court acquitted Gonzaludo of estafa, finding that the deceit did not directly induce the complainant to part with her property, but upheld his conviction for falsification due to his conspiracy with Rosemarie Gelogo in misrepresenting ownership in the deed of sale. The ruling highlights the necessity for deceit to be the efficient cause for estafa to be established.

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8 views2 pages

G.R. No. 150910: Gonzaludo vs. People

The case G.R. No. 150910 involves Bienvenido Gonzaludo, accused of estafa through falsification of a public document related to a house owned by Ulysses Villaflor. The Supreme Court acquitted Gonzaludo of estafa, finding that the deceit did not directly induce the complainant to part with her property, but upheld his conviction for falsification due to his conspiracy with Rosemarie Gelogo in misrepresenting ownership in the deed of sale. The ruling highlights the necessity for deceit to be the efficient cause for estafa to be established.

Uploaded by

lloyd
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No. 150910: Gonzaludo vs.

People

Facts:
The case involves Bienvenido Gonzaludo, who was accused of estafa through
falsification of a public document concerning a house owned by Ulysses Villaflor.
Ulysses was married to Anita Manlangit, but he had a mistress named Rosemarie
Gelogo.
In December 1978, Ulysses purchased a small house in Bacolod City, which he later
improved, increasing its value significantly.
After Ulysses passed away in January 1992, Rosemarie Gelogo offered to sell the
now two-story house to Gonzaludo for P80,000. Initially uninterested, Gonzaludo
convinced the spouses Gregg and Melba Canlas to buy the house, introducing them
to Rosemarie.
On January 20, 1993, a Deed of Sale was executed, where Rosemarie
misrepresented herself as "Rosemarie G. Villaflor," claiming to be the lawful owner
of the house.
Anita Manlangit, Ulysses's widow, later filed a complaint against Rosemarie, the
Canlases, and Gonzaludo, leading to charges of estafa through falsification of a
public document.

Issue:
Whether Gonzaludo was criminally liable for estafa through falsification of a
public document.

Ruling:

The Supreme Court modified the decision of the Court of Appeals, acquitting
Bienvenido Gonzaludo of the complex crime of estafa through falsification of a
public document.
The Court found that while there were elements of fraud committed by Rosemarie
Gelogo, who misrepresented herself as the owner of the house, the essential
element of estafa—specifically, that the deceit must be the efficient cause inducing
the offended party, Anita Manlangit, to part with her property—was not established.
The Court emphasized that for a conviction of estafa, it is crucial that the deceit
occurs prior to or simultaneously with the fraudulent act and that it must directly
induce the offended party to part with their property. In this case, the deceit was
directed at the Canlas spouses, who purchased the house, not at Anita Manlangit,
the complainant. Therefore, the Court acquitted Gonzaludo of the charge of estafa.
However, the Court upheld the conviction for falsification of a public document, as
there was sufficient evidence showing that Gonzaludo conspired with Rosemarie to
falsify the deed of sale by making untruthful statements regarding ownership.

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