People v. Maleza
REITERATIONFacts
The Antecedents: Luciano Maleza, as municipal treasurer of Sevilla, Bohol, certified an account for P249.35 on May 31, 1906, for payments to carpenters and for nails used in the construction of the municipal building during 1903 and 1904. This account was approved by the municipal council. Maleza certified that the services were necessary for the public interest and the articles were recorded. Gabriel Adlaon's signature appeared on the document, indicating he received the amount as a balance due. However, Maleza failed to state the truth, as the money was drawn and paid to Maleza himself, being commissioned to collect a loan made by P. Cayetano Bastes to the municipal president and treasurer in 1903. Adlaon also failed to tell the truth with reckless negligence, stating he received the money when it was neither paid for the carpenters' work nor received by him. Procedural History: A complaint was filed charging Maleza and Adlaon with falsification of a public document by reason of reckless negligence. The accused demurred, arguing the facts did not constitute a crime, the complaint was not lawful, and two crimes were charged. The trial court sustained the demurrer, holding that falsification of a public document by reckless negligence does not exist. The fiscal appealed. The Petition: The fiscal appealed the trial court's decision sustaining the demurrer.
Issue(s)
Whether the crime of falsification of a public document can be committed through reckless negligence under the Penal Code.
Ruling
The Supreme Court reversed the order of the trial court sustaining the demurrer and ordered that the case be remanded for further proceedings.
Ratio Decidendi
On Issue 1: The Supreme Court held that the crime of falsification of a public document through reckless negligence is perfectly legal and cognizable under the law. Applying Article 568 of the Penal Code, the Court explained that there exists a category of punishable acts between those done with malice and those done unconsciously; these are acts performed with lack of foresight, carelessness, or negligence. The Court emphasized that every person must exercise due reflection and caution in their acts to avoid incurring punishment. Under the theory of the Penal Code, he who executes through reckless negligence an act that would otherwise be a grave crime if done with malice shall be punished accordingly. The Court noted that the penalty depends on the relative seriousness of the underlying act, such as homicide or falsification, regardless of the absence of criminal intent. Citing various judgments from the Supreme Court of Spain, the Court affirmed that the classification of falsification by reckless negligence is consistent with established jurisprudence.
Main Doctrine
Falsification of a public document can be committed through reckless negligence, and the Penal Code provides for penalties for such acts, even in the absence of malice or criminal intent.