Case Digest (G.R. No. 34061)
Facts:
- Felipe N. Concepcion was convicted of falsification of a public document by the Court of First Instance of Manila.
- The events occurred on June 28, 1928, while Concepcion was a deputy clerk in the court.
- Criminal case No. 36516, titled "The People of the Philippine Islands vs. Victoriano Mata," was scheduled for trial.
- Concepcion approached Mata, suggesting he could facilitate a guilty plea to avoid trial.
- Mata had only P35 of the P200 fine, which Concepcion accepted, assuring him he would handle the situation.
- Over the following months, Mata paid Concepcion an additional P19.
- In November 1929, Concepcion returned P34 to Mata, claiming he was no longer involved in the case.
- Mata was arrested on January 2, 1930, due to an outstanding warrant for failing to pay the fine.
- Concepcion wrote "6/28/28" on the cover of the criminal case record, misleading court officials about Mata's status.
Issue:
- (Unlock)
Ruling:
- The trial court did not err in crediting the testimony of Victoriano Mata.
- The cover of the criminal case record No. 36516 is considered a public document.
- The act of writing "6/28/28" ...(Unlock)
Ratio:
- The Supreme Court upheld the trial court's decision, affirming the credibility of Mata's testimony despite defense claims of contradictions.
- Mata's discrepancies were attributed to an affidavit prepared by Concepcion, which he felt pressured to sign.
- The court found Mata's account credible, supported by the case's circumstances.
- Although the printed cover...continue reading
Case Digest (G.R. No. 34061)
Facts:
The case involves Felipe N. Concepcion, who was convicted of falsification of a public document by the Court of First Instance of Manila. The events leading to the conviction occurred on June 28, 1928, when Concepcion was serving as a deputy clerk in the first branch of the court. On that day, criminal case No. 36516, titled "The People of the Philippine Islands vs. Victoriano Mata," was scheduled for trial. While Mata awaited his case, Concepcion approached him and suggested that he could facilitate a guilty plea, thereby avoiding a trial. Concepcion inquired if Mata had sufficient funds to pay the imposed fine of P200, to which Mata replied he only had P35. Concepcion then accepted the P35 and assured Mata that he would take care of the situation, leading Mata to believe that his case would not be heard. Over the next few months, Mata provided Concepcion with additional payments totaling P19.
In November 1929, Concepcion returned P34 to Mata, claiming he no longer had any involvement with the case. However, Mata was arrested on January 2, 1930, due to an outstanding warrant for his failure to pay the fine. The crux of the prosecution's case was that Concepcion had written "6/28/28" on the cover of the criminal case record after the printed words "date of commitment," which misled court officials into believing that Mata was serving his sen...