On November 24, 1992, William Sato, a Japanese national, defrauded his deceased wife’s mother,

Manolita Gonzales Vda De Carungcong (79), who was already blind. William made her sign and
thumbmark a special power of attorney authorizing his daughter, Mitsuko Sato (then 20) to sell, assign,
transfer, or dispose to anyone the properties of Gonzales at Tagaytay. William made Manolita believe
that the document involved only taxes. Mediatrix Carungcong, the duly appointed administratix of the
intestate estate of her now deceased mother, Manlolita, filed a complaint against her brother in law,
William. William was able to sell the properties through Mitsuko, collected an amount exceeding ₱22
million and failed to account for the same and never delivered the proceeds to Manolita who died in
1994. William Sato is accused of estafa, but he moved to quash the information, claiming that his
relationship to Manolita as his mother in law was an exempting circumstance (Article 332 of the Revised
Penal Code).

Issue:

W/N The death of Zenaida, who was the wife of William Sato, dissolved the relationship by affinity of
William Sato and Manolita., making Article 332 inapplicable to William.

W/N William Sato can avail of Article 332 in his favor.

Held:

No, the relationship by affinity is not dissolved. Article 332 provides for a absolutory cause in the crimes
of theft, estafa, and malicious mischief. It limits the responsibility of the offender to civil liability only. In
the American legal system, there are two views on the subject – one is that relationship by affinity is
terminated by the death of a spouse. The view supported by most judicial authorities is that if the
spouses have no living issues or children, and a spouse dies, then the relationship of affinity is dissolved.
On the other hand, if the spouses have children, then the relationship by affinity is continued. Because
of the principle of in dubio pro reo, or when in doubt, rule for the accused, the second view is applied.

No, William Sato cannot avail of Article 332 in his favor. Article 332, which is limited to the felonies
mentioned, plainly and unmistakably shows that it applies only to simple crimes. This situation is
complexed with another crime as estafa through falsification of public documents. Since the crime that
William Sato was charged with was not simple estafa, William cannot avail of Article 332’s provisions in
his favor. His crimes of estafa and falsification were not separate but component crimes of a single
complex crime. The accused is found guilty.