G.R. No. L-7236 - People vs. Po Giok To

Defendant-appellee Po Giok To was charged in the Court of First Instance of Cebu for the crime of falsification under an information dated around January 7, 1952.
The information alleged that Po Giok To, with intent to falsify a public document, misrepresented himself to a representative of the City Treasurer of Cebu to issue Residence Certificate No. A-1618529 under the name Antonio Perez, declaring a place of birth as Jaro, Leyte, and citizenship as Filipino.
It was alleged that the true identity of Po Giok To was as a Chinese citizen born in Amoy, China, and thus the document was falsified.

The accused filed a motion to quash on grounds that the information failed to allege two essential elements:

The accused’s obligation to disclose the truth in the document allegedly falsified.
The accused’s wrongful intent to injure a third person.

The City Fiscal opposed, asserting the information sufficiently alleged all elements of the offense.
The lower court found the motion to quash meritorious and ordered amendment of the information.
Subsequently, the lower court dismissed the case without prejudice, citing insufficient evidence that the accused used the falsified residence certificate.

The Government appealed the dismissal, contesting the sufficiency of the information and the legal grounds for dismissal.

Whether or not the information sufficiently alleges the crime of falsification of a public document.
Whether the failure to allege (1) the obligation to disclose the truth and (2) the wrongful intent to injure a third party renders the information insufficient.
Whether a private individual can be held liable under the law for falsification of a public document by inducing a public employee to commit the act.
Whether the special law on residence certificates (Commonwealth Act No. 465) precludes the application of the Revised Penal Code in this case.