People v. Leyson
REITERATIONFacts
The Antecedents: The defendant, Simplicio Leyson, was charged with falsification of a public document as a public official. The charge alleged that on or about January 15, 1904, in Manila, Leyson, an employee in the department of assessments and collections, unlawfully, feloniously, falsely, fraudulently, and corruptly falsified a public and official document, specifically an industrial tax receipt, by counterfeiting the signature of J.Y. McCartey, the chief of the division, without McCartey's participation. Leyson received payment for industrial taxes from a Chinaman named Si Cho and promised to deliver the receipt later. He subsequently delivered a receipt (Exhibit A) bearing the forged signature of J.Y. McCartey. Evidence showed Leyson had access to blank receipts and had delivered similar receipts with forged signatures to other individuals. Procedural History: The inferior court found Leyson guilty of falsification of a public document as an individual, not as a public official, and sentenced him to seven years of presidio mayor. Leyson appealed this decision. The Petition: The defendant appealed the decision of the inferior court, contending that his actions did not constitute falsification of a public document because there was no attempt to imitate the signature of J.Y. McCartey.
Issue(s)
Whether the defendant, an employee in the public service, can be considered a public official for the purpose of the crime of falsification of a public document. Whether the counterfeiting of the signature of J.Y. McCartey on an industrial tax receipt constitutes falsification of a public document. Whether there was a sufficient attempt to imitate the signature of J.Y. McCartey to warrant a conviction for falsification.
Ruling
The Supreme Court reversed the judgment of the inferior court, finding the defendant guilty of falsifying a public document as a public official. The defendant was sentenced to imprisonment for twelve years and one day of cadena temporal, a fine of 1,250 pesetas, and to pay the costs.
Ratio Decidendi
On the issue of whether the defendant was a public official: The Court held that the defendant, Simplicio Leyson, was a public functionary within the provisions of Article 401 of the Penal Code. Although he was an employee and not a public official in the strict sense of having authority vested by public position, his appointment as a clerk in the assessor and collector's office and the performance of public duties connected to his employment qualified him as a public functionary. The Court reasoned that a public official is defined as one who takes part in the exercise of public functions by virtue of law, popular election, or appointment by competent authority. Leyson's duties were in their nature public duties, thus bringing him within this definition. On the issue of whether the counterfeiting constituted falsification of a public document: The Court affirmed that the receipts issued by the department of assessments and collections of the city of Manila are public documents. Therefore, when the defendant falsified these receipts by counterfeiting the signature of J.Y. McCartey, he committed the crime of falsification of a public document. The Court found sufficient evidence, including Leyson's access to blank receipts, his personal receipt of money, and the delivery of forged receipts, to establish his guilt. On the issue of whether there was an attempt to imitate the signature: The Court found that there was a manifest attempt on the part of the defendant to imitate the true signature of J.Y. McCartey. This conclusion was reached by comparing the forged signature on Exhibit A with McCartey's genuine signature on Exhibit F. The Court distinguished this case from previous rulings (United States vs. Paraiso, United States vs. Roque, and United States vs. Buenaventura) which held that no conviction for falsification could occur without an attempt to imitate, by stating that in this instance, such an attempt was evident. The Court's examination of the signatures convinced them of the defendant's intent to mimic McCartey's handwriting.
Main Doctrine
An employee in the public service who counterfeits the signature of a superior on a public document, with the intent to imitate, is guilty of falsification of a public document, even if not a public official in the strict sense, if the act performed involves public duties.