Fullero v. People
REITERATIONFacts
The Antecedents: Petitioner Ernesto M. Fullero, while serving as Acting Chief Operator of the Bureau of Telecommunications Office (BTO) in Iriga City from 1982 to 1994, accomplished and submitted a Personal Data Sheet (PDS) dated January 8, 1988. In this PDS, he stated that he passed the Civil Engineering Board Examination on May 30-31, 1985, with a rating of 75.8%. Subsequently, he applied for positions requiring licensed civil engineers. An inquiry with the Professional Regulation Commission (PRC) revealed that petitioner never passed the civil engineering board examination and his name does not appear in the registry of civil engineers. Petitioner denied accomplishing and submitting the PDS, disowning the signature and thumbmark, and claimed the typewriter used had only capital letters, unlike the PDS which had both. He also alleged ill motive on the part of a subordinate who filed the case. Procedural History: The Regional Trial Court (RTC), Branch 6, Legazpi City, found petitioner guilty of falsification of public document under Article 171, paragraph 4 of the Revised Penal Code, sentencing him to imprisonment and a fine. The Court of Appeals (CA) affirmed the RTC decision in toto. Petitioner appealed to the Supreme Court. The Petition: Petitioner sought to set aside the CA decision, raising issues regarding sufficiency of evidence, criminal intent, admissibility of evidence, and territorial jurisdiction.
Issue(s)
Whether the Court of Appeals erred in sustaining the RTC's judgment despite the alleged absence of sufficient evidence proving the petitioner actually performed the act of falsification. Whether the Court of Appeals erred in sustaining the RTC's judgment, considering that even if the petitioner filled up the PDS with the statement about being a licensed engineer, he was under no obligation to state such data and no criminal intent was shown. Whether the Court of Appeals erred in sustaining the RTC's judgment despite the admission of evidence not properly identified. Whether the Court of Appeals erred in sustaining the RTC's judgment, arguing that the RTC lacked jurisdiction because the venue should have been in Iriga City, not Legazpi City.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals in toto. The petitioner was found guilty beyond reasonable doubt of falsification of public document.
Ratio Decidendi
On the sufficiency of evidence and proof of falsification: The Court held that an accused can be convicted based on sufficient circumstantial evidence even without an eyewitness. The testimonies of witnesses familiar with petitioner's handwriting and signature, coupled with documentary evidence showing striking similarities between the signature on the PDS and petitioner's signatures on other authentic documents, established the falsification. The Court noted that the PDS contained accurate personal data and employment history, which only the petitioner could have known, further supporting the conclusion that he prepared and signed it. The defense of bare denials was deemed insufficient against the prosecution's positive evidence. On the absence of obligation and criminal intent: The Court clarified that wrongful intent to injure a third person is not an essential element of falsification of public document. The crime punishes the violation of public faith and the destruction of truth. The petitioner, as a public officer, had a legal obligation to disclose the truth in his PDS, especially since he was applying for positions requiring licensed civil engineers and affirmed his statements under penalty of perjury. The falsity of his claim was established by PRC records and his own admission of not passing the examination. The fact that the false statement did not cause prejudice or redound to his benefit was inconsequential. On the admissibility of evidence: The Court found the documentary evidence admissible. Certifications from the PRC were admitted as official records and prima facie evidence of facts stated therein, falling under an exception to the hearsay rule. The PDS was considered the original falsified document, not a mere machine copy. Transcripts of stenographic notes from a previous case were admitted as prima facie correct official entries. Certified true copies of documents from the Civil Service Commission were admissible as originals were in the custody of a public office. Signatures on daily time records were admissible for comparison, and the Court reiterated that resort to handwriting experts is not mandatory, as familiarity with the handwriting is sufficient for comparison. On jurisdiction and venue: The Court affirmed that the RTC of Legazpi City had territorial jurisdiction. The information alleged the falsification was committed in Legazpi City, and the submission of the PDS to the BTO in Legazpi City established the locus criminis there. The Court reiterated that where essential acts for the crime occur in different jurisdictions, the court of either jurisdiction may try the case, with the first court to take cognizance excluding others. The petitioner's claim that the PDS was accomplished in Iriga City was unsubstantiated.
Main Doctrine
A public officer who makes untruthful statements in a Personal Data Sheet (PDS), a public document, by falsely claiming to have passed a professional licensure examination, commits falsification of public document under Article 171, paragraph 4 of the Revised Penal Code, especially when such act is done by taking advantage of their official position. The wrongful intent to injure a third person is not an essential element for this crime.