G.R. No. 74226-27 - People vs. Reyes

The case involves the People of the Philippines as the petitioner and Mizpah R. Reyes as the respondent.
The controversy centers on the alleged falsification of a public document—specifically, a notarized deed of sale.
The deed of sale was executed on May 19, 1961, and registered with the Register of Deeds of Lipa City on May 26, 1961.
The property in question was originally owned by Julio Rizare and Patricia Pampo, who were the parents of both the accused Mizpah R. Reyes and the complainants (Cristina R. Masikat, Julieta R. Vergara, and Aurora Rizare Vda. de Ebueza).

In June 1983, the complainants allegedly discovered from the Register of Deeds that the property had been transferred into the name of Mizpah R. Reyes.
The complainants observed that the notarized deed of sale purportedly executed by their deceased parents contained irregularities.
Specific findings included the alleged forgery of Patricia Pampo’s signature and an untruthful indication that Mizpah Reyes was single, despite her marriage to Benjamin Reyes on May 2, 1950.
The document was subsequently referred to the National Bureau of Investigation (NBI), which confirmed that while Julio Rizare’s signature was genuine, Patricia Pampo’s signature was forged.

The fiscal, acting upon the complaint, filed two criminal informations on October 18, 1984:

Criminal Case No. V-1163 for falsification regarding the signature of Patricia Pampo.
Criminal Case No. V-1164 for making an untruthful statement about Mizpah Reyes’ marital status.

Before arraignment, the accused filed a motion to quash the informations on two grounds:

The criminal action had been extinguished by the prescription of the crime.
Lack of jurisdiction due to non-compliance with the pre-conciliation requirement under P.D. No. 1508.

The trial court granted the motion to quash the charges, holding that the prescriptive period had already lapsed, as it started on the date of registration (May 26, 1961) through the doctrine of constructive notice.
The Court of Appeals later affirmed the trial court’s decision, maintaining that the prescriptive period commenced from the deed’s registration.

It is firmly established that a public document, once registered, serves as constructive notice to the world.
Relevant statutes and case law, including provisions in the Revised Penal Code (Art. 172 and Art. 90) and cases such as Cabral v. Puno and Gatioan v. Gaffud, support the initiation of the prescriptive period from the date of registration.
The principle embodies the notion that no one can plead ignorance of what a public record conveys.

Whether the crime of falsification of a public document has prescribed given that the prescriptive period is set at ten (10) years.
The pivotal question centers on when the prescriptive period commenced—whether on the actual discovery in June 1983 or on the registration date (May 26, 1961) of the deed of sale.

Whether the doctrine that registration in a public registry constitutes constructive notice to the world should be applied in a criminal prosecution for falsification.
The issue includes whether this principle effectively sets the prescriptive period from the date of registration rather than from the later actual discovery by the complainants.

The accused’s contention that the trial court lacked jurisdiction due to the pre-conciliation requirement of P.D. No. 1508.
The proper interpretation and application of the prescriptive provisions under the Revised Penal Code in light of the arguments raised by both parties.