People v. Concepcion
REITERATIONFacts
The Antecedents: The accused, Felipe N. Concepcion, was a deputy clerk of the Court of First Instance of Manila. He allegedly approached Victoriano Mata, a defendant in a criminal case (No. 36516), and offered to help him plead guilty and avoid trial. Concepcion asked Mata for money, claiming he would take care of the case. Mata gave Concepcion P35, and later P10 and P4. Concepcion later returned P34 to Mata, stating he no longer had anything to do with the branch where Mata was convicted. Mata was not committed to jail until January 2, 1930, despite a warrant issued on December 3, 1929. Concepcion had written "6/28/28" after "date of commitment" on the cover of criminal case record No. 36516. Procedural History: The Court of First Instance of Manila convicted Felipe N. Concepcion of falsification of a public document and sentenced him to eight years and one day of prision mayor, a fine of P1,000, and costs. The Petition: The accused appealed the judgment, assigning errors related to the credibility of Victoriano Mata's testimony, the classification of the criminal record cover as a public document, and whether the act of writing the date constituted falsification.
Issue(s)
Whether the testimony of Victoriano Mata should be given credit. Whether the cover of criminal case record No. 36516 is a public document. Whether the act of writing the figures "6/28/28" after the words "date of commitment" constitutes the crime of falsification of a public document.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance of Manila in its entirety, upholding the conviction of Felipe N. Concepcion for falsification of a public document.
Ratio Decidendi
On the credibility of Victoriano Mata's testimony: The Court found no reason to doubt the veracity of Mata's testimony. While there appeared to be a contradiction between his affidavit and his court testimony, Mata explained that the affidavit was prepared by the accused, Concepcion, who implored him to sign it out of pity as it was his "only salvation." This explanation, elicited by the defense counsel, resolved the apparent contradiction. The Court gave credence to Mata's testimony regarding the alleged corrupt transaction. On whether the cover of criminal case record No. 36516 is a public document: The Court held that the printed cover, once filled in by a proper court official and attached to the record, becomes part of the record and is converted into a public document. The data thereon serve as a brief note on important proceedings and a guide to the court and its officials. The Court emphasized that officials rely on these data in their daily routine. The accused, aware of this reliance, used it to conceal his malfeasance in collecting money from Victoriano Mata, as the date "6/28/28" on the cover led the clerk to believe Mata was serving subsidiary imprisonment when he was at large. On whether the act of writing the figures "6/28/28" constitutes falsification of a public document: The Court ruled that the act did constitute falsification. The writing of the figures "6/28/28" after "date of commitment" altered the full meaning of the cover and the effect it should produce. It misrepresented Mata's status as being in confinement when he was actually at large. This falsity affected the entire record, preventing the clerk of court from collecting the fine imposed, as he would have been able to if Mata had appeared to be in prison. Therefore, the alteration of such data or the writing of falsehoods constitutes falsification.
Main Doctrine
The cover of a criminal record, containing data on proceedings and dates, forms part of the record and is a public document. Alteration or falsification of such data constitutes falsification of a public document.