Title
Gimenez vs. People
Case
G.R. No. 214231
Decision Date
Sep 16, 2020
A 25-year employee, accused of falsifying a corporate resolution, was acquitted by the Supreme Court due to lack of criminal intent and reliance on superior’s instructions.

Case Digest (G.R. No. 182976)
Expanded Legal Reasoning Model

Facts:

Marilyn Y. Gimenez, a long‐time employee and de facto corporate secretary of Loran Industries, a furniture manufacturing and exporting firm, was charged with falsification of a public document. The dispute centers on a Secretary’s Certificate she executed on August 25, 2003. Originally, a Board resolution dated June 19, 2003 mandated a two‑signatory policy for issuing checks from the company’s Allied Bank accounts. However, the August 25 certificate, allegedly executed without authorization of an actual meeting or proper Board resolution, allowed checks to be issued with only one signatory. Testimonies revealed that:
  • Petitioner had worked for over 25 years and held significant positions but had no formal appointment as corporate secretary.
  • The certificate contradicted the prior two‑signatory policy, and its issuance led to checks being drawn with a single signature.
  • Several witnesses, including members of the Board (Lorna and Antonio) and employees (Camilo), confirmed that no meeting or proper Board resolution had been held on August 15, 2003 to justify the one‑signature policy.
  • Petitioner testified that she was merely following the instructions of her immediate superior, Paolo, a son of the company’s owners, as the company was experiencing liquidity problems. She further claimed that the actions taken were to alleviate delays and financial challenges arising from the two‑signatory policy.
  • Moreover, evidence showed that the Board of Directors was aware of the certificate and even benefited from it by authorizing checks with one signature on occasions, calling into question the element of malice.

Issues:

The primary issue is whether petitioner's execution of the August 25, 2003 Secretary’s Certificate, authorizing the release of checks with only one signature contrary to the valid two‑signatory Board resolution, constitutes falsification of a public document. In connection with this, the Court had to determine:
  • Whether there was criminal intent (malice) in her actions.
  • Whether her role as a mere employee acting under instructions negated the element of deliberate deceit required for the crime of falsification.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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