G.R. No.

164457 April 11, 2012

ANNA LERIMA PATULA, Petitioner,

vs.
PEOPLE OF THE PHILIPPINES, Respondent.

The complex crime of Estafa Through Falsification of Documents is committed when one
has to falsify certain documents to be able to obtain money or goods from another person.
In other words, the falsification is a necessary means of committing estafa. However, if
the falsification is committed to conceal the misappropriation, two separate offenses of
estafa and falsification are committed.

G.R. No. 159381 March 26, 2010

DANILO D. ANSALDO, Petitioner,

vs.
PEOPLE OF THE PHILIPPINES, Respondent.

For a complex crime of estafa through falsification of a public document to prosper, all the
elements of both the crimes of estafa and falsification of a public document must exist.

G.R. No. 179448 June 26, 2013

CARLOS L. TANENGGEE, Petitioner,

vs.
PEOPLE OF THE PHILIPPINES, Respondent.

When the offender commits on a public, official or commercial document any of the acts
of falsification enumerated in Article 171 as a necessary means to commit another crime
like estafa, theft or malversation, the two crimes form a complex crime.
The falsification of a public, official, or commercial document may be a means of
committing estafa, because before the falsified document is actually utilized to defraud
another, the crime of falsification has already been consummated, damage or intent to
cause damage not being an element of the crime of falsification of public, official or
commercial document. In other words, the crime of falsification has already existed.
Actually utilizing that falsified public, official or commercial document to defraud another
is estafa. But the damage is caused by the commission of estafa, not by the falsification
of the document. Therefore, the falsification of the public, official or commercial document
is only a necessary means to commit estafa.

G.R. No. 181409 : February 11, 2010

 INTESTATE ESTATE OF MANOLITA GONZALES VDA. DE CARUNGCONG,
represented by MEDIATRIX CARUNGCONG, as Administratrix, Petitioner, v.
PEOPLE OF THE PHILIPPINES and WILLIAM SATO, Respondents.

The phrase "necessary means" does not connote indispensable means for if it did, then
the offense as a "necessary means" to commit another would be an indispensable
element of the latter and would be an ingredient thereof. In People v. Salvilla, the phrase
"necessary means" merely signifies that one crime is committed to facilitate and insure
the commission of the other.
When the offender commits in a public document any of the acts of falsification
enumerated in Article 171 of the Revised Penal Code as a necessary means to commit
another crime, like estafa, theft or malversation, the two crimes form a complex crime
under Article 48 of the same Code. The falsification of a public, official or commercial
document may be a means of committing estafa because, before the falsified document
is actually utilized to defraud another, the crime of falsification has already been
consummated, damage or intent to cause damage not being an element of the crime of
falsification of a public, official or commercial document. In other words, the crime of
falsification was committed prior to the consummation of the crime of estafa. Actually
utilizing the falsified public, official or commercial document to defraud another is estafa.
The damage to another is caused by the commission of estafa, not by the falsification of
the document.