People v. Barreto
REITERATIONFacts
The Antecedents: The accused, Tomas F. Barreto, was charged with falsification of a private document, specifically a pawn ticket issued by the Monte de Piedad y Caja de Ahorros de Manila. The information alleged that Barreto erased the name "Tomas Barreto" and substituted "Valentin Aguirre," changed the pawn amount from "eight pesos" to "one thousand, two hundred pesos," altered the valuation figures from "P10" to "P1,600," and changed the description of the pawned item from "an American five dollar gold piece" to "An 18 carat gold finger-ring, set with a brilliant of ordinary size, and a pair of 18 carat gold ear-rings, set with two brilliants of ordinary size and 16 small brilliants." These alterations were made with the intent to injure an unknown person to whom Barreto delivered the pawn ticket as security for a loan, and to prejudice the Monte de Piedad. Procedural History: The accused pleaded "guilty" and was convicted and sentenced by the lower court. He appealed the decision. The Petition: The appellant assigned two errors: (1) the court erred in holding that the crime of falsification of a private document was committed despite the place of commission not being alleged or proven, and (2) the court erred in holding that the crime was committed despite the true name of the person intended to be injured being omitted from the complaint and not proven.
Issue(s)
Whether the crime of falsification of a private document was committed despite the place of commission not being alleged or proven. Whether the crime of falsification of a private document was committed despite the true name of the person intended to be injured being omitted from the complaint and not proven.
Ruling
The judgment of conviction and sentence are affirmed. The Supreme Court found no error in the proceedings prejudicial to the rights of the appellant.
Ratio Decidendi
On the first issue (place of commission): The information expressly charged the defendant with falsification of a private document in the city of Manila, Philippine Islands, which is within the jurisdiction of the trial court. The plea of "guilty" constituted an admission of this allegation. Under Article 304 of the Penal Code, the crime of falsification of a private document is consummated at the time and place where the document is falsified to the prejudice of or with the intent to prejudice a third person. The subsequent improper or illegal use of the falsified document is not a material or essential element of the crime. Therefore, the place where the document is actually falsified is the place of the commission of the crime, and the allegation of the crime being committed in a specific place is sufficient. On the second issue (identity of the injured party): The information charged that the offense was committed with intent to prejudice not only an unknown person but also the "Monte de Piedad y Caja de Ahorros de Manila." Even without reference to the Monte de Piedad, it is sufficient to allege that the crime was committed with intent to prejudice a third person, even if their name is unknown. Article 304 of the Penal Code allows for conviction upon proof of intent to injure a third person, regardless of whether that person's name is known. The appellant's theory that a criminal prosecution cannot be maintained without a private complainant, or that an unknown injured party must be presumed not to have filed a sworn complaint, is erroneous. The proceedings were based on an information filed by the public prosecuting officer, who has the authority to institute criminal actions without regard to the intervention of private persons directly injured, except for private offenses. Subsection 5 of section 6 of General Orders No. 58 provides that an information is sufficient if it states the names of the persons against whom the offense was committed, if known, implying that the omission of the name when unknown does not render the information insufficient.
Main Doctrine
The crime of falsification of a private document is consummated at the time and place where the document is falsified to the prejudice of or with the intent to prejudice a third person, regardless of whether the falsified document is subsequently put to the improper or illegal use for which it was intended. The improper or illegal use of the document thereafter is not a material or essential element of the crime.