People v. Reyes
REITERATIONFacts
The Antecedents: The spouses Julio Rizare and Patricia Pampo owned a parcel of land. They had four children, including the accused Mizpah R. Reyes and the complainants Cristina R. Masikat, Julieta R. Vergara, and Aurora Rizare Vda. de Ebueza. In May 1961, a notarized deed of sale was executed, purportedly by Julio Rizare and Patricia Pampo, selling the land to Mizpah R. Reyes. This deed was registered with the Register of Deeds on May 26, 1961. The complainants alleged that they discovered this deed in June 1983 and found that their parents' signatures were falsified, specifically Patricia Pampo's, and that Mizpah R. Reyes falsely declared herself as single when she was already married. An NBI report confirmed Patricia Pampo's signature was forged. Two informations for falsification of public document were filed on October 18, 1984. Procedural History: The accused filed a motion to quash the informations, arguing that the crime had prescribed and that the court lacked jurisdiction due to non-compliance with pre-conciliation requirements. The Regional Trial Court (RTC) granted the motion, quashing the informations, holding that the ten-year prescriptive period began from the registration of the deed of sale on May 26, 1961, and thus the crime had prescribed by the time the informations were filed over twenty years later. The People appealed to the Court of Appeals (CA), which affirmed the RTC's decision, rejecting the argument that the prescriptive period should commence from the actual discovery in June 1983. The Petition: The People, through the Solicitor-General, filed a petition for review on certiorari, questioning the CA's ruling that the prescriptive period for falsification of a public document begins from the date of registration, citing the principle of constructive notice, and arguing that the statement in Cabral v. Puno was merely an obiter dictum.
Issue(s)
Whether the crime of falsification of a public document has prescribed. Whether the ten (10) year prescriptive period for falsification of a public document commences from the date of registration of the falsified document with the Register of Deeds, applying the rule on constructive notice, or from the actual discovery by the offended party.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed. The crime of falsification of a public document has prescribed.
Ratio Decidendi
On whether the crime of falsification of a public document has prescribed: The Court affirmed the ruling of the Court of Appeals, holding that the crime had indeed prescribed. The crime of falsification of a public document, punishable by prision correccional, prescribes in ten (10) years under Article 90 of the Revised Penal Code. The prescriptive period commences from the day the crime is discovered by the offended party, the authorities, or their agents, as provided in Article 91 of the Revised Penal Code. On whether the ten (10) year prescriptive period for falsification of a public document commences from the date of registration of the falsified document with the Register of Deeds, applying the rule on constructive notice, or from the actual discovery by the offended party: In this case, the falsified document, a notarized deed of sale, was registered with the Register of Deeds on May 26, 1961. The criminal informations were filed on October 18, 1984. The core issue was when the discovery of the crime should be deemed to have occurred. The Court reiterated the well-established rule that registration in a public registry serves as notice to the whole world, and the record constitutes constructive notice of its contents. This principle, consistently applied in civil cases, was deemed applicable to criminal actions when the facts and legal circumstances warrant, particularly in determining the commencement of the prescriptive period. The Court found that the registration of the deed of sale on May 26, 1961, constituted constructive notice to the offended parties, thus marking the commencement of the prescriptive period. Since more than ten years had elapsed from May 26, 1961, until the filing of the informations on October 18, 1984, the crime had prescribed. The Court emphasized that applying the rule on constructive notice is favorable to the accused, as it leads to an earlier reckoning of the prescriptive period, aligning with the principle that the interpretation most favorable to the accused should be adopted in criminal cases.
Main Doctrine
The ten (10) year prescriptive period for the crime of falsification of a public document commences from the date of discovery, which, in cases involving registered documents, is deemed to be the date of registration with the Register of Deeds, consistent with the rule on constructive notice. Therefore, if the crime is discovered or deemed discovered upon registration and the prescriptive period has lapsed before the filing of the information, the crime has prescribed.