People v Castaneda

Facts:
Benjamin Manaloto was charged with the crime of Falsification of Public Document. The complaint was filed by his wife, Victoria Manaloto.

That on or about the 19th day of May, 1975, in the Municipality of San Fernando, province of Pampanga, Philippines, Benjamin falsified in a deed of sale the house and lot belonging to the conjugal partnership in favor of Ponciano Lacsamana, making it appear that his spouse gave her marital consent to said sale.

At the trial, the prosecution called the wife to the witness stand but the defense moved to disqualify her as a witness, invoking Sec. 20, Rule 130. The prosecution stated that it is a "criminal case for a crime committed by one against the other." Notwithstanding such opposition, respondent Judge granted the motion, disqualifying Victoria.

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:
No. The case is an exception to the marital disqualification rule. WHEN AN OFFENSE DIRECTLY ATTACKS, OR DIRECTLY AND VITALLY IMPAIRS, THE CONJUGAL RELATION, IT COMES WITHIN THE EXCEPTION to the statute that one shall not be a witness against the other except in a criminal prosecution for a crime committed (by) one against the other.

In the case, 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. 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 more reason must the exception apply to the instant case where the victim of the crime and the person who stands to be directly prejudiced by the falsification is not a third person but the wife herself. And it is undeniable that the act 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 disqualifying 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, 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.