Lastrilla v. Granda
REITERATIONFacts
The Antecedents: Respondent Rafael Granda, grandson and heir of the deceased spouses Rafael and Aurora Granda, filed a complaint for falsification of public documents against petitioner Robert Lastrilla and others. The complaint stemmed from three (3) Deeds of Absolute Sale, all dated December 7, 1985, purportedly selling parcels of land owned by Aurora Granda to petitioner's siblings and to petitioner and his spouse. Respondent alleged that the signatures of his deceased grandparents on these deeds were falsified, that the deeds were antedated, and that petitioner conspired in their falsification by signing as an instrumental witness and subsequently causing their registration. Procedural History: The Office of the City Prosecution of Tacloban initially dismissed the complaint against petitioner, his spouse, and siblings, finding no probable cause. However, upon respondent's petition for partial review, the Department of Justice (DOJ) modified this resolution, finding probable cause against petitioner. The Court of Appeals (CA) further modified the DOJ's resolution, directing the Office of the Prosecutor to file three (3) informations charging petitioner with Falsification of Public Document under Article 172 (1), in relation to Article 171 (1), (2), and (5) of the Revised Penal Code. Petitioner sought reversal of the CA's decision. The Petition: Petitioner argued that the CA gravely erred in finding probable cause against him, contending that the finding was based merely on allegations unsubstantiated by evidence.
Issue(s)
Whether there is probable cause to believe that petitioner Robert Lastrilla committed the crime of Falsification of Public Document under Article 172 (1), in relation to Article 171 (1), (2), and (5) of the Revised Penal Code; including the consideration of criminal intent, damage, good faith, and authorization. Whether the CA gravely erred in finding probable cause against petitioner.
Ruling
The petition is DENIED. The July 18, 2003 Decision of the Court of Appeals in CA-G.R. No. 26273 is AFFIRMED.
Ratio Decidendi
On the existence of probable cause for Falsification of Public Document, the alleged lack of criminal intent and damage, and the defense of good faith and authorization: The Court found that probable cause exists against petitioner. Petitioner signed as an instrumental witness to the Deeds of Absolute Sale, attesting that the vendors, the Granda spouses, signed in his presence on December 7, 1985. However, petitioner admitted that the negotiations for the sales began in 1998, indicating the deeds were antedated. Furthermore, the PNP Crime Laboratory report concluded that the specimen signatures of the deceased grandfather did not match those on the deeds, and the grandfather had already died in June 1989, making his signature on the December 7, 1985 deed impossible. The Court noted the presumption that a person intends the ordinary consequences of his voluntary act, which is significant for petitioner, who was tasked with ensuring the authenticity of the signatures. The Court also found sufficient evidence that petitioner was responsible for registering the falsified deeds, causing the cancellation of the old titles, and effecting the issuance of new titles in the names of the vendees, as evidenced by certifications from the Register of Deeds showing he presented the deeds for registration and received them upon release. The Court rejected petitioner's defense that Aurora Granda caused the registration, as it was a bare assertion without corroboration. The possession and use of a forged document create a presumption that the possessor is the forger. The Court rejected petitioner's reliance on the DOJ's finding that the absence of criminal intent and damage negated falsification, clarifying that the validity of the sale transactions was disputed by the respondent. Criminal intent is a mental state shown by overt acts, and the absence of damage does not necessarily negate falsification. The violation of public faith and the destruction of truth are the primary concerns. The Court dismissed petitioner's defense of good faith and authorization, noting it was raised belatedly and contradicted by the respondent. The probable falsification of signatures and antedating of documents cast serious doubt on the claim of Aurora's authorization. On the alleged grave error of the CA: The Court reiterated its policy not to interfere with preliminary investigations but noted exceptions when acts are without or in excess of authority, and found that the CA's determination of probable cause was supported by facts and reason.
Main Doctrine
The Court affirmed the Court of Appeals' finding of probable cause against petitioner Robert Lastrilla for falsification of public document. The Court held that petitioner's act of signing as an instrumental witness to antedated deeds of sale, despite probable cause to believe the signatures were falsified, coupled with his subsequent act of registering these deeds to effect the transfer of titles, constituted evidence of malice and willful transgression of the law, establishing a prima facie case for falsification.