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People vs. Castañeda, G.R. No. 208290, Dec. 11, 2013

Victoria filed a complaint against her husband Benjamin for falsifying her signature on a deed of sale for their marital home. At trial, the defense sought to prevent Victoria from testifying under the rule preventing spouses from testifying against each other without consent. The court held that this was an exception as it was a criminal case for a crime committed by one spouse against the other. Falsifying the signature damaged the marital relationship and harmony was already gone. Therefore, there was no risk of perjury and the marital disqualification rule did not apply.

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141 views1 page

People vs. Castañeda, G.R. No. 208290, Dec. 11, 2013

Victoria filed a complaint against her husband Benjamin for falsifying her signature on a deed of sale for their marital home. At trial, the defense sought to prevent Victoria from testifying under the rule preventing spouses from testifying against each other without consent. The court held that this was an exception as it was a criminal case for a crime committed by one spouse against the other. Falsifying the signature damaged the marital relationship and harmony was already gone. Therefore, there was no risk of perjury and the marital disqualification rule did not apply.

Uploaded by

chara escano
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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People vs. Castañeda, G.R. No. 208290, Dec.

11, 2013

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. 

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