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02 People vs Castañeda, Manaloto the criminal act complained of had the effect of directly and vitally

G.R. No. L-46306. February 27, 1979 impairing the conjugal relation.
TOPIC: Disqualification by reason of marriage  Public policy demands that the wife should not be disqualified from
(Parian) testifying against her husband in a case of falsification of public document
Petition for certiorari. constituted by the husband against his wife.
1. Victoria Manaloto filed a complaint against her husband, Benjamin  To rule the contrary view would spawn the dangerous precedent of a
Manaloto for Falsification of Public Documents husband committing many falsifications against his wife as he could
2. Benjamin forged Victoria’s signature in a deed of absolute sale of a house conjure, seeking shelter in the anti-marital privilege as a license to injure
and lot belonging to the spouses’ conjugal property. and prejudice in secret — all with unabashed and complete immunity.
3. At the trial, prosecution called Victoria to the witness stand but the defense
moved to disqualify her as a witness, invoking Sec. 20, Rule 130 of ROC:
SEC. 20. Disquali􏰁cation by reason of interest or NOTES:
relationship. — The following persons cannot testify as to SC cited a rape case wherein the wife was allowed to testify against her husband who
matters in which they are interested, directly or indirectly, raped their daughter; stating that the crime committed against the daughter is a crime
as herein enumerated: committed against the wife (well not literally; just SC being dramatic) --- “for the
xxx xxx xxx reason that said criminal act "positively undermined the connubial (or matrimonial)
(b) A husband can not be examined for or against his wife relationship."
without her consent; nor a wife for or against her husband
without his consent, except in a civil case by one against
the other, or in a criminal case for a crime committed by
one against the other.
4. Prosecution opposed the said motion on the ground that the case
falls under the exception to the rule, contending that it is a
“criminal case for a crime committed by one against the other”.
5. Notwithstanding the opposition, Judge Castañeda granted the
motion. MR denied. Hence, this certiorari.

ISSUE: WON Victoria is disqualified to testify against her husband by reason of


marriage as per the Rules of Court. NO

HELD:

 A criminal case for Falsification of Public Document filed against the


husband—who allegedly forged the signature of his wife in a deed of sale,
thereby making it appear that the latter gave her marital consent to the sale
of a house and lot belonging to their conjugal partnership when in fact and
in truth she did not — 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.
 It is the husband's breach of his wife's confidence which give rise to the
offense charged, for if the sale had been made with the consent of the wife,
no crime could have been charged against the husband. This is the same
breach of trust which prompted the wife to make the necessary complaint.
 Where the victim of the crime and the person who stands to be directly
prejudices by the falsification is not a third person but the wife herself the
exception to the marital disqualification rule applies for it is undeniable that