Case Digest (G.R. No. L-13142)
Facts:
- The case involves the People of the Philippines as the plaintiff-appellee and Felix Manansala y Lopez as the accused-appellant.
- On August 13, 1954, Manansala was driving TPU jeepney No. 3873 along P. Paterno Street, Quiapo, Manila.
- He was apprehended by Corporal Vicente del Rosario of the Manila Police Department (MPD) for driving outside his authorized route.
- Manansala presented a duplicate copy of Traffic Violation Report (TVR) No. 277957, issued as a temporary driver's permit by MPD patrolman P. Purificacion due to his third traffic violation.
- Corporal del Rosario noticed alterations on the TVR, specifically the erasure of "III" and "three" replaced with "I" and "one," making it appear Manansala had only one pending traffic violation instead of three.
- During the investigation, Manansala admitted to making the alterations to avoid arrest for a fourth traffic violation.
- At trial, he denied responsibility, claiming he did not understand the confession he signed, which was in English.
- The Court of First Instance of Manila found Manansala guilty of falsification of an official document and sentenced him to imprisonment and a fine.
- Manansala appealed to the Court of Appeals, which then certified the case to the Supreme Court as it involved points of law.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the decision of the lower court, finding no sufficient reason to reverse the conviction of Felix Mana...(Unlock)
Ratio:
- The Supreme Court held that the falsified TVR was issued to Manansala and was in his possession from its issuance until he was caught committing a fourth traffic violation.
- The court applied the established rule that possession and use of a falsified document justify the presumption that the possessor is the forger.
- Manansala's inability to explain the falsification further supported this presumption.
- Manansala had a strong motive to commit the falsification to avoid arrest for a fourth traffic violation, as the MPD policy was to arrest drivers on their fourth viol...continue reading
Case Digest (G.R. No. L-13142)
Facts:
The case involves the People of the Philippines as the plaintiff-appellee and Felix Manansala y Lopez as the accused-appellant. On August 13, 1954, Manansala was driving TPU jeepney No. 3873 along P. Paterno Street, Quiapo, Manila, when he was apprehended by Corporal Vicente del Rosario of the Manila Police Department (MPD) for driving outside his authorized route. Manansala presented a duplicate copy of Traffic Violation Report (TVR) No. 277957, which had been issued to him as a temporary driver's permit by MPD patrolman P. Purificacion due to his third traffic violation. Corporal del Rosario noticed alterations on the TVR, specifically the erasure of the figure "III" and the word "three" and their replacement with "I" and "one," respectively. This alteration made it appear that Manansala had only one pending traffic violation instead of three. During the investigation, Manansala admitted to making the alterations to avoid arrest for a fourth traffic violation. However, at the trial, he denied responsibility, claiming he did not understand the confession he signed, which was in English. The Court of First Instance of Manila found...