People v. Terrado
REITERATIONFacts
The Antecedents: In November 1951 and May 1952, Gertrudes Obo, Remedios Gundran, and Mariano Terrado applied for and were issued free patents for contiguous parcels of land in Barrio Paculago, Ragay, Camarines Sur, each exceeding 23 hectares. These lands were allegedly forest land and thus not disposable. Procedural History: On March 13, 1962, separate informations were filed charging Mariano Terrado, Remedios Gundran, Gertrudes Obo, Pedro Terrado (a licensed private land surveyor), Casimiro Flores (a public land inspector), and Bruno Gundran (District Land Officer) with falsification of public documents under Article 171 of the Revised Penal Code. They were accused of conspiring to prepare false documents, including applications for free patent, notices of application, final inspection reports, and indorsements, to make it appear that the applicants met the legal requirements for free patents, when in truth and in fact, they knew these representations to be false. Casimiro Flores and Bruno Gundran allegedly took advantage of their official positions. The Petition: Before arraignment, the defendants filed motions to quash the informations, arguing that the charged crimes did not constitute falsification of public documents and that the offenses had already prescribed. The trial court dismissed the informations, ruling that the crimes had prescribed.
Issue(s)
Whether the acts charged constitute falsification of public documents under Article 171 of the Revised Penal Code. Whether the criminal actions for the alleged offenses have prescribed.
Ruling
The Supreme Court affirmed the dismissal of the informations. It held that while the informations sufficiently alleged falsification of public documents, the offenses had already prescribed. The Court applied the principle that penal statutes are strictly applied against the government and liberally in favor of the accused, opting for the more favorable interpretation that the acts were punishable as perjury under Commonwealth Act No. 141, and that the prescriptive periods for offenses penalized by special laws, as provided in Public Act No. 3326, as amended, had elapsed.
Ratio Decidendi
On whether the acts charged constitute falsification of public documents under Article 171 of the Revised Penal Code: The Court acknowledged that the informations sufficiently alleged the commission of falsification of public documents under Article 171 of the Revised Penal Code. However, this finding was secondary to the issue of prescription. The Court noted that the preparation and submission of false affidavits in support of claims respecting public lands are also punishable as perjury under Section 129 of Commonwealth Act No. 141. On whether the criminal actions for the alleged offenses have prescribed: The Court ruled that the criminal actions had prescribed. It reasoned that falsification of public documents, punishable by prision mayor (an afflictive penalty), prescribes in 15 years. Perjury, under Article 183 of the Revised Penal Code, is punishable by arresto mayor to prision correccional (correctional penalty) and prescribes in 10 years. However, Public Act No. 3326, as amended, provides that violations penalized by special laws prescribe according to specific periods. For offenses punishable by imprisonment of two years or more but less than six years, the prescriptive period is eight years. Since perjury under Section 129 of Commonwealth Act No. 141 carries a penalty of imprisonment from four months and one day to two years and four months, it falls under the category prescribing in eight years. Given that the offenses were alleged to have been committed between November 1951 and February 1953, and the informations were filed on March 13, 1962, more than eight years had passed, thus the crimes had prescribed.
Main Doctrine
The Court affirmed the dismissal of the informations for falsification of public documents, holding that the offenses had prescribed. It reasoned that the acts charged were also punishable as perjury under Commonwealth Act No. 141, and applying the prescriptive periods for offenses penalized by special laws, the criminal actions had already expired.