People v. Wilson
REITERATIONFacts
The Antecedents: The defendants, Joseph L. Wilson and Alfredo Dolores, employees of the San Carlos Milling Company, were accused of falsifying a telegraphic dispatch to instruct a bank to deposit $100,000 for the account of San Carlos Milling Co., Ltd. They were also accused of falsifying a check for P200,000 against the Bank of the Philippine Islands, forging the signature of the company manager, Newland Baldwin, and subsequently collecting the amount. Additionally, they were charged with falsifying a Manager's Check of the China Banking Corporation for P200,001, again forging Newland Baldwin's signature on the indorsement. Procedural History: The trial court found Alfredo Dolores guilty as principal, in conspiracy with Joseph L. Wilson, of the crimes of falsification of a telegraphic dispatch, estafa through falsification of a mercantile document, and falsification of a mercantile document. Dolores was sentenced to imprisonment for each offense, with accessory penalties and fines. Dolores appealed the judgment. The Petition: The defendant Alfredo Dolores appealed, arguing that the trial court erred in holding that he intended to benefit himself and damage another, and in holding that he defrauded and damaged the San Carlos Milling Co., Ltd., and the Bank of the Philippine Islands. His counsel argued that Dolores was merely carrying out the orders of his superior, Joseph L. Wilson, and should be exempt from criminal responsibility.
Issue(s)
Whether Alfredo Dolores is exempt from criminal responsibility for merely following the orders of his superior, Joseph L. Wilson. Whether Alfredo Dolores defrauded and damaged the San Carlos Milling Co., Ltd., and the Bank of the Philippine Islands.
Ruling
The judgment of the trial court finding Alfredo Dolores guilty of the crimes charged is affirmed. The accessory penalties and costs are also affirmed against the appellant.
Ratio Decidendi
On the issue of following orders: The Court held that Alfredo Dolores is not exempt from criminal responsibility. For such exemption to apply, both the person giving the order and the person executing it must act within the limitations prescribed by law. The evidence clearly showed that Dolores took direct part in, and cooperated with, his co-defendant Wilson in the preparation of the falsified documents and in cashing the check. He received P10,000 as his share of the embezzled amount, demonstrating his knowledge of and participation in the criminal intent. Furthermore, Dolores's behavior subsequent to the commission of the crimes, including his secret conversations with Wilson, his hiding from authorities, registering under a false name, and attempting to flee the country, are circumstances indicative of his guilt. The Court cited U.S. vs. Sarikala and U.S. vs. Virrey for the principle that flight is a circumstance indicative of guilt. On the issue of defrauding and damaging the companies: The Court found this assignment of error to be without merit, particularly concerning the charge of estafa through falsification of a mercantile document. The conspirators absconded with P200,001, and it is immaterial whether the loss fell directly on the San Carlos Milling Co., Ltd., or the Bank of the Philippine Islands; it is sufficient that a person or persons other than the perpetrators sustained the loss. The Court noted that the trial court made no pronouncement as to indemnity, thus civil responsibility was not involved in the appeal.
Main Doctrine
An employee who directly participates in the preparation and negotiation of falsified documents, and who receives a share of the embezzled funds, cannot claim exemption from criminal responsibility by merely asserting that they were following orders from a superior. The subsequent flight of the accused after the commission of the crime is a circumstance indicative of guilt.