G.R. No. L-26057 - People vs. Bautista

Two criminal informations were filed by the City Fiscal’s Office of Pasay City against respondent Rosita Flores Dabu.
The charges were for the crime of falsification of public documents by means of false narration of facts pursuant to Article 172, in relation to Article 171, of the Revised Penal Code.
Two separate informations were involved:

Criminal Case No. 6708-P – alleging that on March 19, 1961, a certificate of live birth for Susan Dabu de Vera was prepared, executed, and signed by the accused, wrongly attesting that she and Quinciano de Vera entered into marriage at Lubao, Pampanga, on September 23, 1958, thereby giving legitimacy to the child born on that day.
Criminal Case No. 6709-P – alleging that on September 13, 1962, a certificate of live birth for Quinciano Dabu de Vera, Jr. was similarly prepared, executed, and signed, again falsely asserting a marriage between the accused and the complainant.

In both cases, the falsified documents contained assertions that the respective child was born out of a lawful marriage that never took place.
The essence of the charge was that Rosita Flores Dabu knowingly issued birth certificates which misrepresented the marriage status of the parties, rendering the documents formally public yet substantively fraudulent.
It was contended that the inaccuracies in the birth certificate details—specifically the date of filing, entry number, and in one case the date of the child’s birth—were untruthful statements intended to legitimize the supposed marriage and the legitimacy of the child.

The child’s birth date from “September 13, 1962” to “September 12, 1962” within the body of the information.
The witness list to substitute the birth certificate of Susan Dabu de Vera with that of Quinciano de Vera, Jr.

The amendments aimed to accurately reflect the actual entries in the Civil Register of Pasay City without altering the substantive facts of the alleged fraud.

After arraignment and a plea of not guilty by the accused, the prosecution’s motion to amend the informations was raised before trial proceedings began.
The trial court (Court of First Instance of Rizal, Pasay City, Branch III), under Judge Pedro JL. Bautista, refused the proposed amendments, which the accused argued would prejudice her rights.
The trial court’s decision was later reasserted through a denial of a motion for reconsideration.
As a result, the prosecution sought a writ of certiorari and a writ of preliminary injunction from this Court, aiming to halt further proceedings until a final decision on the amendments was reached.
The Supreme Court granted the preliminary injunction on May 18, 1966, and reviewed the propriety of allowing the amendments.

Whether the amendments proposed by the prosecution—namely, changing dates and entry numbers in the informations—are purely formal corrections or whether they alter the substantive nature of the alleged offense.

Does altering the filing date (from March 20 to March 29, 1961) and the entry number (from Entry No. 907 to Entry No. 807) in Criminal Case No. 6708-P affect any constitutive element of the crime of falsification of public document?
In Criminal Case No. 6709-P, will the amendment changing the alleged child’s birth date (from September 13, 1962 to September 12, 1962) and substituting the corresponding birth certificate affect the essence of the charge alleging falsification?

Whether the refusal to allow these amendments by the trial court constituted an abuse of discretion, thereby prejudicing the accused’s rights as provided under the rules of criminal procedure.

Was the amendment merely designed to correct clerical mistakes without altering the core allegation of false narration of facts in the public documents?
Did the amendments prejudice the defense, particularly considering that the substantive elements of the falsification charge (i.e., the non-existence of the alleged marriage) remain unchanged?

Whether the prosecution is unconstitutionally precluded from introducing evidence (such as a different birth certificate) than that originally disclosed, under the provisions of Revised Rule 116, Section 1.