G.R. No. 31012 - People vs. Romualdez

The People of the Philippine Islands filed charges against Estela Romualdez and Luis Mabunay for falsification of public and official documents.
Estela Romualdez was then secretary to Supreme Court Justice Norberto Romualdez and had custody of bar examination compositions and related documents. Luis Mabunay was a candidate who took the 1926 Bar Examinations.
The criminal act involved the illegal extraction, alteration, and falsification of Mabunay’s bar examination compositions, specifically raising his grades from 58% to 64% in Remedial Law and from 63% to 73% in Civil Law, to secure his passing average and admission to the Bar.

Justice Norberto Romualdez was chairman of the 1926 Bar Exam Committee. Various attorneys were appointed to prepare examination questions and to grade the compositions (correctors).
Estela Romualdez also acted as one of the correctors (Political Law) and was regarded as a supervisor over the correctors along with Deputy Clerk Jeronimo Samson.
The compositions were graded blindly: candidates were assigned numbers, and their names were sealed in envelopes to maintain anonymity during grading.

Estela Romualdez admitted to altering the grades on Mabunay’s compositions but claimed she did so under the authority given by Justice Romualdez to “revise the compositions already graded” for the purpose of doing justice, provided revisions occurred before the candidates’ names were known.
Justice Romualdez testified that he gave Estela Romualdez supervisory powers to revise grades to correct injustices, but without precise limits or written instructions and without requiring her to report alterations.
Estela denied knowing Mabunay prior to trial.
The prosecution challenged the legality and scope of this authority and asserted she altered grades knowing the candidate to whom the compositions belonged.

After the bar examination results were published, inconsistencies were found between initial grades recorded and those published, specifically concerning Mabunay’s grades.
The grades written on Mabunay’s compositions revealed erasures and rewriting in Estela Romualdez’s handwriting. The erasures preserved the original correctors’ initials, thus creating a false impression that the original correctors made the alterations.
The list of passing candidates included Mabunay with an average of 75% after the alterations, despite prior official computations showing an average below the passing mark.

Mabunay withdrew 600 pesos from his savings shortly before the publication of results. Estela deposited a significant sum shortly after, which she claimed came from a cousin but could not sufficiently substantiate.
Mabunay did not testify or present evidence explaining his withdrawal.

Both were found guilty: Estela as principal and Mabunay as accomplice in falsification.
Sentences imposed included imprisonment, fines, perpetual disqualification from public office for Estela, and corresponding penalties for Mabunay.
Both appealed, raising several assignments of error questioning the legality of the authority conferred, the legitimacy of the documents as public documents, the sufficiency of evidence, and procedural issues.

Whether the act of altering bar examination compositions and grades constituted the falsification of public and official documents under Philippine law.
Whether Estela Romualdez was authorized by Justice Norberto Romualdez to alter examination grades and, if so, whether she acted within the limits of that authority.
Whether Estela Romualdez exercised the supposed authority in good faith and without knowledge of the candidates’ identities at the time of alteration.
Whether Luis Mabunay participated knowingly and willingly in the falsification.
Whether the trial court erred in refusing to admit expert testimony on the proper grading of the compositions.
Whether the appellants were afforded a fair and impartial trial, including their right to a speedy trial.
Whether the penalty imposed on the accused are legally appropriate and commensurate with the offenses.