PEOPLE VS.

CASTAÑEDA

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.

RULING:

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.

UP BOARD OF REGENTS VS. LIGOT- TEYLAN

FACTS:

U.P. Board of Regents issued a Resolution establishing the STFAP (Socialized

Tuition Fee and Assistance Program). All students are entitled to apply for STFAP
benefits. Applicants are required to accomplish a questionnaire and at the end the
application form, the student applicant, as well as his parent, signs a sworn statement –
University may send a fact-finding team to visit my home/residence to verify the veracity
of the information.

Ramon P. Nadal, a student enrolled in the College of Law, availed of STFAP. A

team conducted a home investigation at the residence of Nadal in Quezon City and found
discrepancies between the report and Nadal’s application form. Villanueva (head of the
office of scholarship) wrote Nadal informing him that he had failed to declare, not only the
fact that he had a 1977 Corolla car which was owned by his brother but also the income
of his mother who was supporting his brothers. He reclassified him to Bracket 9 (from
Bracket 4), retroactive to June 1989, unless he could submit “proofs to the contrary.”
Nadal was required “to pay back the equivalent amount of full school fees”.

Because of the discrepancies between Nadal’s application form and the

certification, the U.P. charged Nadal before the Student Disciplinary Tribunal (SDT) that
he willfully withheld and did not declare a car and the income of his mother which acts of
willfully withholding information is tantamount to acts of dishonesty in relation to his
studies.

SDT rendered a decision exculpating Nadal of the charge of deliberately

withholding in his STFAP application form information that he was maintaining a Toyota
Corolla car, but finding him guilty of deliberately withholding information about the income
of his mother. SDT imposed upon Nadal the penalty of expulsion from the University and
required him to reimburse all STFAP benefits he had received but if he does not
voluntarily make reimbursement, it shall be “effected by the University thru outside legal
action.” SDT decision elevated to the Executive Committee of U.P. Diliman for review
which affirmed the decision of the SDT; whereupon, Nadal appealed to the Board of
Regents (BOR). BOR affirmed the decision of the SDT; the penalty was modified “from
Expulsion to One Year- Suspension. Nadal filed a MR of the BOR decision (guilty).
Nadal asked President Abueva not to issue any press release regarding the case and
filed with the RTC of Quezon City a petition for mandamus with preliminary injunction and
prayer for a TRO against President Abueva and the BOR. The lower court ruled that they
are temporarily restrained. Dispensing with the filing of a motion for reconsideration, the
petitioners filed the instant petition for certiorari and prohibition with prayer for the
issuance of an injunction or temporary restraining order.

ISSUE:

Whether or not the respondent judge gravely abused her discretion in issuing the
May 29, 1993 writ of preliminary injunction thereby preventing the BOR from
implementing the suspension penalty it had imposed on Nadal.

RULING:

The Court finds that the lower court gravely abused its discretion in issuing the writ
of preliminary injunction of May 29, 1993. The issuance of the said writ was based on the
lower court’s finding that the implementation of the disciplinary sanction of suspension on
Nadal “would work injustice to the petitioner as it would delay him in finishing his course,
and consequently, in getting a decent and good paying job.” Sadly, such a ruling
considers only the situation of Nadal without taking into account the circumstances clearly
of his own making, which led him into such a predicament. More importantly, it has
completely disregarded the overriding issue of academic freedom which provides more
than ample justification for the imposition of a disciplinary sanction upon an erring student
of an institution of higher learning.