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Co vs. People

LUIS L. CO AND ALVIN S. CO, PETITIONERS, VS. PEOPLE OF THE PHILIPPINES, BANGKO SENTRAL NG PILIPINAS AND PHILIPPINE DEPOSIT INSURANCE CORPORATION, RESPONDENTS.

G.R. No. 233015 | 2019-10-16

D E C I S I O N
BERSAMIN, C.J.:
 
When the information charges the accused to have forged a private document to commit fraud against another, the crime is falsification of a private document instead of estafa. It is the recital of the facts constitutive of the offense, not the designation of the offense in the information, that determines the crime being charged against the accused.

There can be no complex crime of falsification of private documents and estafa because the element of damage essential in both is the same.
 
The Case

We resolve the appeal filed by the petitioners to seek the review and reversal of the...