Case Digest (G.R. No. L-7236)
Facts:
The People of the Philippines v. Po Giok To, G.R. No. L-7236. April 30, 1955, the Supreme Court En Banc, Reyes, J.B.L., J., writing for the Court.In the Court of First Instance of Cebu, Po Giok To (defendant-appellee) was charged by the People of the Philippines (plaintiff-appellant) with falsification under an information alleging that on January 7, 1952 the accused, with intent to falsify a public document, misrepresented his name, place of birth and citizenship to a representative of the City Treasurer of Cebu so that Residence Certificate No. A-1618529 would show the name “Antonio Perez,” place of birth “Jaro, Leyte,” and citizenship “Filipino,” when in truth his name was Po Giok To, born in Amoy, China, and a Chinese citizen.
The accused filed a motion to quash the information on two grounds: (1) the information did not allege that he had any obligation to disclose the truth in the residence certificate, and (2) it did not allege that he had the wrongful intent to injure a third person. The City Fiscal opposed the motion, arguing the information sufficiently alleged the elements of the offense. The trial court deemed the motion meritorious and ordered the information amended; subsequently, however, because the Fiscal insisted the original information was sufficient and stated he had no proof the accused had used the certificate, the court dismissed the case without prejudice.
The Government appealed the dismissal to the Supreme Court. The s...(Pro-only)
Issues:
- Did the information allege sufficient facts to constitute the crime of falsification of a public document under the Revised Penal Code?
- If the information is sufficient, may a private person be criminally liable for falsification of a public document by inducing a public officer to write false entries?
- Does the existence of the special statute on residence certificates, Commonwealth Act No. 465, bar application of the general falsifi...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)