People v. Benito · G.R. 36979

Petitioner: People
Respondent: Benito
Citation: G.R. No. 36979
Court: Supreme Court
Division: En Banc
Ponente: Vickers, J.
Decided: November 23, 1932

Summary

Miguel Benito, cashier of International Harvester Company's Davao branch, was convicted of estafa and falsification of commercial documents. From November 1930 to September 1931, he received P59,486.06 in company funds but deposited only P44,486.05, misappropriating P15,000.01. To conceal the theft, he falsified bank reconciliation statements and other documents. The Supreme Court En Banc affirmed his conviction but treated the offenses as separate crimes rather than a complex crime, ruling that the falsification was not a means to commit estafa but to conceal it. This case established important precedent regarding the distinction between complex crimes and separate offenses, and clarified that going to trial under an information charging multiple offenses constitutes a waiver of objections to the multiplicity of charges.

Statutes applied

Revised Penal Code, Art. 172

Related cases

Other Philippine cases on the same provisions and issues.

Goma v. Court of Appeals G.R. No. 168437
Layno v. People G.R. No. 93842
Constantino v. People G.R. No. 225696
People v. Po Giok To G.R. No. L-7236
Herrera v. Sandiganbayan G.R. No. 217064
Guillergan v. People G.R. No. 185493
Perez v. People G.R. No. 205176
People v. Mendoza G.R. No. L-5563
Terado v. People G.R. No. 238951
Paras v. People G.R. No. 242259
Pastor-Cuevas v. People G.R. No. 242541
Sunga v. People G.R. No. 265764

By the Intellegal Editorial Board · November 23, 1932

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