Case Digest (G.R. No. 93640)
Facts:
In the case of The People of the Philippine Islands vs. Lorenzo Reodica and Sinforoso Cordero (G.R. No. 42557, December 7, 1935), the appellant, Lorenzo Reodica, was convicted by the Court of First Instance of Palawan for the falsification of a public document, specifically the municipal payroll for July 1931. As the municipal treasurer of Bacuit, Palawan, Reodica was accused of making it appear that Sinforoso Cordero, who was the municipal secretary, had rendered services during the period from July 23 to July 31, 1931. The prosecution claimed Cordero was absent from Bacuit during this entire time and had not returned until 1933. The payroll was presented to Reodica by the municipal president, already signed and approved for payment. Alongside the payroll was a letter authorizing the payment of Cordero's salary for the latter half of July, along with documents that indicated Cordero had been granted an eight-day leave from July 23 to July 31. The appellant was accused not
Case Digest (G.R. No. 93640)
Facts:
- Background and Position of the Parties
- Lorenzo Reodica served as the municipal treasurer of Bacuit, Province of Palawan, during July 1931.
- Sinforoso Cordero appeared on the municipal payroll as having rendered services as municipal secretary for the period from July 23 to July 31, 1931, despite evidence to the contrary.
- Events Leading to the Allegation
- The municipal payroll for July 1931 was prepared and submitted by the municipal president, already signed and accompanied by a letter (Exhibit 3) authorizing the payment of Sinforoso Cordero’s salary.
- Additional supporting documents established that Sinforoso Cordero was granted an eight-day leave of absence from July 23 to July 31, 1931, confirming that his services were not actually rendered during that period.
- The Certification and Payment Details
- The payroll was certified by the municipal president, who approved the payment by verifying that the services mentioned in the document had been rendered.
- Although the payroll indicated that Sinforoso Cordero’s salary was paid on July 31, 1931, evidence suggested that the payment may have been made on July 23, 1931, creating a potential discrepancy in the record.
- Allegation and Nature of the Offense
- Lorenzo Reodica was charged with falsification of a public document due to the alleged discrepancies and the appearance of an alteration in the payroll.
- The information against him was based on the contention that he had manipulated the payroll, despite the fact that the certification of services was the responsibility of the municipal president.
Issues:
- Determination of Falsification
- Is the alteration in the payroll, particularly the listing of Sinforoso Cordero’s service, sufficient to constitute the falsification of a public document?
- Did the discrepancy between the dates provided in the payroll (certification of service and the actual payment date) substantiate the charge against the appellant?
- Attribution of Responsibility
- To what extent does the municipal president’s certification of the payroll, asserting that services were rendered, mitigate or transfer the liability from the appellant?
- Does the division of roles—between the municipal treasurer and the municipal president—influence the assignment of guilt in cases of document alteration?
- Significance of the Discrepancy in Dates
- Does the possibility that the payment was made on July 23 instead of July 31 materially affect the overall veracity and legal effect of the payroll?
- Can a difference in the documented payment date, in the presence of proper certification, be legally construed as falsification?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)