G.R. No. 186030 - Delos Reyes Vda. Del Prado vs. People

Petitioners Norma Delos Reyes Vda. Del Prado, Eulogia R. Del Prado, Normita R. Del Prado, and Rodelia R. Del Prado were charged with falsification under Article 172 in relation to Article 171(4) of the Revised Penal Code.
The victims were parties claiming ownership to a parcel of land originally covered by Original Certificate of Title (OCT) No. P-22848 situated in Lingayen, Pangasinan.
Ma. Corazon Del Prado-Lim was a private complainant asserting her right as an heir of the late Rafael Del Prado.

The petitioners were accused of falsifying a Deed of Succession dated July 19, 1991, executed to partition the estate of the late Rafael Del Prado.
The deed falsely stated that the petitioners were the only heirs, excluding Corazon who was also his heir.
The deed led to the cancellation of the original title and issuance of new titles excluding Corazon from ownership.

The prosecution asserted Corazon was the daughter of Rafael by his first wife, Daisy Cragin, and heir to the estate.
Documents such as a Deed of Extra-Judicial Partition (Oct. 29, 1979), Deed of Exchange (Oct. 15, 1982), and Confirmation of Subdivision confirmed Corazon's share.
Witness Loreto L. Fernando testified that petitioners requested and notarized the deed of succession.
Petitioners denied signing the deed or appearing before the notary and claimed Corazon was a niece, not a daughter.
Petitioners admitted to executing a deed of mortgage over portions of the property after new titles were issued.

Municipal Trial Court (MTC) found petitioners guilty beyond reasonable doubt, sentencing them to imprisonment and fines, ordering indemnity for attorney's fees.
Motion for new trial by petitioners was denied by the MTC.
Regional Trial Court (RTC) affirmed MTC's decision but dismissed the case against minor Rodelia.
Court of Appeals (CA) dismissed petitioners' appeal, affirming RTC's decision but modified the penalty under the Indeterminate Sentence Law.
The CA denied petitioners' motion for reconsideration.

Argued that Corazon was not excluded as heir in the various documents executed with petitioners' participation.
Claimed they acted in good faith and that the case was essentially civil, not criminal.
Asserted the presumption of innocence was not overcome by the prosecution.

Whether the Court of Appeals erred in affirming the conviction of the petitioners for falsification despite their defense that they never intended to exclude Corazon as an heir of Rafael Del Prado.
Whether the petitioners' good faith negates the commission of the crime of falsification.
Whether the case should be treated as a civil matter rather than a criminal case.