Estafa Complaint for Forged Receipts in the Philippines: A Comprehensive Legal Guide

I. Introduction

Forged or spurious receipts remain one of the most common instruments of fraud in Philippine commerce—from padded liquidation reports in government offices to “ghost” deliveries in the private sector. When someone is induced to part with money or property on the strength of a fake receipt, the law usually responds with a criminal charge for estafa (swindling) in conjunction with—or sometimes absorbed by—falsification of commercial documents. This article gathers, in one place, the essential doctrines, statutes, procedures, jurisprudence, and practical pointers every lawyer, accountant, entrepreneur, or ordinary consumer should know.

II. Statutory Foundations

Governing Law	Key Provision	Relevance to Forged Receipts
Revised Penal Code (RPC)	Art. 315 – Estafa	Penalizes deceit causing damage; mode (2)(a) covers “false pretences or fraudulent acts” such as issuing fictitious documents.
RPC	Arts. 171–172 – Falsification	Making or using forged receipts is falsification of commercial documents.
RPC	Art. 48 – Complex Crimes	When the same act constitutes both estafa and falsification, the crimes may be treated as estafa through falsification of commercial documents, a single complex offense with the heavier penalty.
National Internal Revenue Code (NIRC)	Secs. 257 & 264	Criminalizes printing, issuing, or using sales invoices/ORs not authorized by the BIR; often charged alongside estafa.
Rules of Criminal Procedure	Rules 110–116	Outline complaint-filing, preliminary investigation, and arraignment/trial.
RA 7691	Expanded MTC jurisdiction	Amounts ≤ ₱1.2 million: MTC/MeTC; > ₱1.2 million: RTC.

III. Elements of Estafa Using Forged Receipts

False pretense or fraudulent representation – e.g., presentation of a fake or altered receipt.
Offender knew it was false and intended to defraud.
Victim relied on the representation and parted with money/property.
Damage or prejudice capable of pecuniary estimation resulted.

Note: The use of a forged receipt supplies both the false pretense (estafa) and the falsified document (falsification).

IV. Relationship Between Estafa and Falsification

Separate but intertwined. The Supreme Court usually complexes them under Art. 48 when the falsified receipt is the very means to commit estafa.
Key rulings:
- People v. Dizon, G.R. 110391 (14 Apr 1999) – conviction for estafa thru falsification for padding purchase orders and receipts.
- People v. Po, G.R. 208444 (03 Feb 2016) – reiterated that private individuals can be liable for falsification of commercial documents, not only public officers.
- People v. Yu, G.R. 242460 (27 Jan 2021) – forged ORs for scrap metal sales; Court emphasized need to prove both deceit and damage.

V. Where and How to File

Demand Letter (best practice): While not an element, a written demand helps establish deceit and damages.
Affidavit-Complaint: Sworn statement with annexes (original forged ORs, expert findings) filed with the Office of the City/Provincial Prosecutor where:
- the deceitful representation was made or
- the payment/property was delivered.
Preliminary Investigation: Respondent submits counter-affidavit; prosecutor resolves probable cause.
Information: If probable cause exists, an Information for estafa through falsification (or separate Informations) is filed in the proper court.
Arraignment & Trial: Prosecution must establish guilt beyond reasonable doubt; forensic examiners from the NBI Questioned Documents Division or PNP Forensic Group usually testify.

VI. Evidentiary Pitfalls and Best Practices

Issue	Practical Tip
Authentication of Receipt	Bring the original; photocopies invite objections under the Best Evidence Rule (Rule 130, § 3).
Expert Examination	Secure a questioned-document report early; courts give great weight to expert testimony on handwriting, ink dating, serial-number irregularities, or thermal-paper inconsistencies.
BIR Certification	A Certification that an OR is not registered, or that the serial number belongs to another taxpayer, is powerful corroboration.
Quantum of Proof	– Preliminary Investigation: only probable cause. – Trial: proof beyond reasonable doubt of both falsification and deceit/damage.

VII. Penalties and Civil Liability

Amount Defrauded	Penalty for Estafa (Art. 315 as amended by RA 10951)
≤ ₱40,000	Arresto Mayor (1 mo-6 mos) + fine 5×–2 × value
> ₱40,000 – ₱1.2 M	Prisión Correccional (6 mos-6 yrs)
₱1.2 M – ₱2.4 M	Prisión Mayor (6 yrs-12 yrs)
> ₱2.4 M	Reclusión Temporal (12 yrs-20 yrs)

Falsification adds prisión correccional (2 yrs-6 yrs) and a fine, but in a complex crime the higher penalty (estafa) is applied, raised by one degree (Art. 48).

Civil liability for the amount defrauded, interest, and damages automatically attaches (Art. 100, RPC; Art. 1157, Civil Code).

VIII. Prescription

Estafa: Depends on penalty actually imposable. E.g., if the amount exceeds ₱2.4 M (reclusión temporal) → 15 years from discovery of crime (Art. 90, RPC).
Falsification: 10 years (prisión correccional). The period pauses while accused is outside the Philippines (Art. 91).

IX. Available Defenses

Receipt is genuine – challenge prosecution’s expert.
No deceit or reliance – victim knew receipt was fake.
No damage – payment later refunded (but note: restitution may mitigate but does not erase criminal liability).
Novation of obligation – rarely prospers unless novation extinguished liability before prosecution.
Good faith – e.g., accused merely a conduit with no knowledge of forgery.

X. Corporate & Officer Liability

A corporation itself cannot be imprisoned, but may be fined (e.g., under NIRC).
Corporate officers, bookkeepers, and agents who personally issued or caused the forged receipts face personal criminal liability.
Courts pierce the veil where corporate fiction is used as a shield for fraud.

XI. Tax & Administrative Consequences

BIR may assess deficiency VAT/income tax against both issuer and user of fake receipts.
Licenses and permits can be revoked by LGUs or regulatory agencies.
Public officers may additionally incur administrative and Sandiganbayan liability for graft.

XII. Recent Jurisprudential Trends

Case	G.R. No.	Date	Key Take-Away
People v. Yu	242460	27 Jan 2021	Receipt falsification need not be alleged separately; complex crime deemed alleged if facts show it.
People v. Lihaylihay	191219	13 Jan 2020	Conviction despite absence of demand; delivery of property sufficed to show damage.
People v. Dominguez	246309	12 July 2022	Court reiterated that private individuals may be guilty of falsification of commercial documents even without intent to gain; intent presumed.

XIII. Practical Compliance & Prevention Tips

Digitize Receipts – QR-coded BIR-accredited sales systems reduce forgery risk.
Vendor Due Diligence – verify Accreditation Certificate & BIR Permit to Use.
Segregation of Duties – separate receiving, recording, and auditing functions.
Prompt Verification – banks can authenticate deposit slips within 24 hours; delay weakens estafa cases.
Legal Audit Clause – include a contractual right to inspect and authenticate supporting documents.

XIV. Conclusion

Filing—and winning—an estafa complaint grounded on forged receipts demands meticulous documentary evidence, expert support, and timely action. While the Revised Penal Code supplies the core offenses, a successful prosecution often hinges on practical steps taken long before trial: preserving originals, obtaining forensic reports, and synchronizing criminal, civil, and tax remedies. Armed with the legal principles and tactical insights outlined above, complainants and counsel can navigate the Philippine justice system with greater confidence and efficiency.

Disclaimer: This article is for general informational purposes only and does not constitute legal advice. Consult a qualified Philippine lawyer for advice on specific facts or situations.