Case Digest: G.R. No.

L-19192 (February 28, 1923)

Title: The People of the Philippine Islands vs. Miguel G. Concepcion

Parties:

Plaintiff-Appellee: The People of the Philippine Islands

Defendant-Appellant: Miguel G. Concepcion

Facts:

● Miguel G. Concepcion was found guilty of estafa (fraud) through falsification of

mercantile documents.
● Concepcion, a representative in the Philippine Assembly, needed funds and used
fictitious warehouse receipts to obtain loans from the Philippine National Bank.
● Teodorico Angeles, the manager of a bank branch, colluded with Concepcion in this
scheme.
● Abelardo Crisologo and Ricardo Paredes were also involved; they were implicated as
joint principals but seemed to be more victims than active participants.
● Crisologo was persuaded by Concepcion and Angeles to appear as a borrower for the
loan in the form of warehouse receipts for tobacco.
● The first loan was secured by a warehouse receipt and promissory notes signed by
Crisologo; the second loan involved another warehouse receipt for tobacco supposedly
deposited in Baggao.
● The tobacco did not actually exist, and Crisologo did not profit from the loans.

Issues:

● Whether Miguel G. Concepcion should be held guilty of estafa through falsification of

mercantile documents.
● Whether the conviction under subsection 5 of article 535 of the Penal Code was
appropriate when the information alleged an estafa based on deceit under subsection 1
of article 535.

Ruling:

● Yes, Miguel G. Concepcion was correctly found guilty of estafa through falsification of
mercantile documents.
● The conviction was appropriate under subsection 5 of article 535 of the Penal Code,
even though the information alleged estafa based on deceit under subsection 1 of article
535.
Analysis:

● Miguel G. Concepcion was found guilty of estafa through the falsification of mercantile
documents. He collaborated with Teodorico Angeles to secure loans using fictitious
warehouse receipts for tobacco. Concepcion induced Abelardo Crisologo to participate
in this scheme.
● Crisologo signed promissory notes and warehouse receipts, but he did not benefit from
the loans, and the tobacco did not exist. This shows Concepcion's active role in
orchestrating the fraud.
● The court affirmed the conviction under subsection 5 of article 535, which refers to
fraudulent misapplication of funds. Despite the information alleging estafa based on
deceit (subsection 1 of article 535), the court held that a conviction under subsection 5
was appropriate given the circumstances. The responsible bank manager knew the
tobacco was non-existent, making the case more aligned with subsection 5, which
focuses on fraudulent misapplication.
● The court modified the period of imprisonment imposed by the trial judge to align with the
true legal requirement.

Conclusion:
● In the case of G.R. No. L-19192, the Supreme Court upheld the conviction of Miguel G.
Concepcion for estafa through falsification of mercantile documents. The court affirmed
the application of subsection 5 of article 535 of the Penal Code for the conviction, even
though the information alleged a different subsection. The court modified the period of
imprisonment to be in accordance with the legal requirements.