People v. Reodica
REITERATIONFacts
The Antecedents: The appellant, Lorenzo Reodica, was the municipal treasurer of Bacuit, Palawan, in July 1931. He was charged with falsifying the municipal payroll for that month by making it appear that Sinforoso Cordero rendered services as municipal secretary from July 23 to July 31, 1931, when Cordero was actually absent during that period. Procedural History: The Court of First Instance of Palawan sentenced the appellant to an indeterminate penalty of two years of prision correccional to eight years and one day of prision mayor for falsification of a public document. The Petition: The appellant appealed the decision of the Court of First Instance.
Issue(s)
Whether the appellant is guilty of falsification of a public document. Whether the alterations made to the payroll constitute falsification.
Ruling
The appealed judgment is reversed, and the appellant is acquitted, with costs de oficio.
Ratio Decidendi
On Whether the appellant is guilty of falsification of a public document: The evidence disclosed that the municipal payroll was submitted to the appellant already prepared, signed, and approved by the municipal president, with the president's certification that the services mentioned were rendered. The appellant's role was to process the payment based on this certification. Therefore, the appellant is not guilty of falsification as alleged because the president, not he, certified that the services were rendered. Furthermore, even if the appellant made alterations, such alterations, if they did not affect the veracity or effects of the document, do not constitute the crime of falsification. On Whether the alterations made to the payroll constitute falsification: The information alleged that the appellant falsified the payroll by making it appear that Sinforoso Cordero rendered services from July 23 to July 31, 1931, when he was absent. However, the payroll was submitted to the appellant already signed and approved by the president, who certified that the services were rendered. The appellant's act of processing the payment, even if he made some alterations, did not constitute falsification because the veracity of the document was not affected, especially since Cordero was granted a leave of absence for that period, which, for the purpose of salary payment, amounted to his having rendered services. The information also stated that the appellant certified the payment on July 31, 1931, but it did not allege that this was untrue. Even if the payment was made on July 23, it was immaterial whether it was done on July 23 or July 31, as Cordero was in fact paid. The Supreme Court cited Decisions of the Supreme Court of Spain of February 25, 1885, and June 21, 1886, stating that such alterations, even if attributable to the appellant, do not affect the veracity or effects of the document and do not constitute the crime of falsification.
Main Doctrine
A municipal treasurer is not guilty of falsification of a public document, such as a payroll, if the document was already prepared, signed, and approved by the municipal president, and the treasurer's only act was to process the payment based on the president's certification that the services were rendered. Alterations that do not affect the veracity or effects of the document do not constitute falsification.