Domingo v. People

Summary

This Supreme Court case affirmed the conviction of dentist Gina Domingo for 17 counts of Estafa through Falsification of Commercial Document. Over a 13-month period (1995-1996), Domingo forged bank encashment slips using the signature of Remedios Perez, her landlord and family friend, withdrawing ₱838,000 from Perez's BPI account. The scheme was discovered when Perez attempted to withdraw money and found her account depleted. Expert handwriting analysis confirmed the signatures were forged, showing significant divergences in stroke structure and execution. The Supreme Court upheld the lower courts' findings that all elements of both crimes were present, ruling that the falsification was a necessary means to commit estafa, forming a complex crime. The Court rejected Domingo's defense of denial and theory of bank inside job, emphasizing that positive identification by credible witnesses prevails over bare denials. The case establishes important precedents on handwriting expert testimony standards and the presumption that applies when someone possesses and profits from falsified documents.