Practice question
An offender falsifies a public authorization and uses it to obtain another person’s property through a proved estafa scheme. The falsification is established as the means facilitating that estafa. Which category applies, absent another governing special rule?
- Only a compound crime based on one indivisible physical movement.
- Necessarily two unrelated offenses.
- No offense because a document was used.
- Complex crime proper under the necessary-means branch.
- A civil mistake regardless of the proved criminal elements.
Legal references
- Revised Penal Code, Article 48 as amended, text and current two-branch rule reproduced in People v Reyes, G.R. No. 260030, May 19, 2025: https://lawphil.net/judjuris/juri2025/may2025/gr_260030_2025.html
- Intestate Estate of Manolita Gonzales Vda. de Carungcong v People, G.R. No. 181409, February 11, 2010, main decision, necessary means and falsification-estafa: https://lawphil.net/judjuris/juri2010/feb2010/gr_181409_2010.html
- People v Sendaydiego, G.R. Nos. L-33253 and L-33254, January 20, 1978, main decision, falsification to conceal malversation distinguished from necessary means: https://lawphil.net/judjuris/juri1978/jan1978/gr_33254_1978.html
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