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People vs. Castaneda Case Digest


Facts:

Victoria filed a complaint for Falsification of Public Document against her husband, Benjamin. Victoria alleged that Benjamin falsified her signature in a deed of sale of a house belonging to the conjugal partnership, making it appear that she gave her marital consent to said sale. At the trial, the prosecution called to the witness stand Victoria, but the defense moved to disqualify her as a witness, invoking the rule that a spouse cannot be examined without the consent of the other spouse, except in a civil case by one against the other or in a criminal case for a crime committed by one against another. The prosecution opposed the motion on the ground that the case falls under the exception, contending that it is a criminal case committed by one against the other. The trial court granted the motion, disqualifying Victoria from testifying against Benjamin. Their motion for reconsideration denied, the prosecution elevated the case to the Supreme Court on pure question of law


Issue:

Whether or not the criminal case for Falsification of Public Document may be considered as a criminal case for a crime committed by a husband against his wife and, therefore, an exception to the rule on marital disqualification.


Held:

Yes. The case is an exception to the marital disqualification rule, as a criminal case for a crime committed by the accused-husband against the witness-wife.

The act complained of as constituting the crime of Falsification of Public Document is the forgery by the accused of his wife's signature in a deed of sale, thereby making it appear therein that said wife consented to the sale of a house and lot belonging to their conjugal partnership when in fact and in truth she did not. It must be noted that had the sale of the said house and lot, and the signing of the wife's name by her husband in the deed of sale, been made with the consent of the wife, no crime could have been charged against said husband Clearly, therefore, it is the husband's breach of his wife's confidence which gave rise to the offense charged. And it is this same breach of trust which prompted the wife to make the necessary complaint with the Office of the Provincial Fiscal which, accordingly, filed the aforesaid criminal case. To rule, therefore, that such criminal case is not one for a crime committed by one spouse against the other is to advance a conclusion which completely disregards the factual antecedents of the instant case.

It is undeniable that the act complained of had the effect of directly and vitally impairing the conjugal relation. This is apparent not only in the act of the wife in personally lodging her complaint with the Office of the Provincial Fiscal, but also in her insistent efforts in connection with the instant petition, which seeks to set aside the order disqualified her from testifying against her husband. Taken collectively, the actuations of the witness-wife underscore the fact that the martial and domestic relations between her and the accused-husband have become so strained that there is no more harmony to be preserved said nor peace and tranquility which may be disturbed. In such a case, the "identity of interests disappears and the consequent danger of perjury based on that identity is nonexistent. Likewise, in such a situation, the security and confidence of private life which the law aims at protecting will be nothing but Ideals which, through their absence, merely leave a void in the unhappy home. Thus, there is no reason to apply the martial disqualification rule. (People vs. Castaneda, G.R. No. L-46306, February 27, 1979)

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