G.R. No. 244816 - Gonzaga vs. Commission on Audit

On August 13, 1954, Felix 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 allegedly driving outside his authorized route.

Upon being asked to present his driver’s license, Manansala showed the duplicate copy of TVR No. 277957, which had been issued earlier as a temporary driver’s permit following his third traffic violation.
The document in question underwent alterations: the original figure “III” and the word “three” indicating pending traffic violation cases were erased or obliterated and replaced by the numeral “I” and the word “one.”

Corporal del Rosario, noticing the alterations, secured Manansala for further investigation in the MPD Records Section.
An investigation confirmed that the alterations changed the apparent number of pending cases from three to one.
Manansala admitted to making the alterations initially, purportedly to conceal his previous offenses and avoid immediate arrest should he commit a fourth violation.
This admission was documented in an extra-judicial confession (Exhibit C), which was duly signed by the accused and entered as evidence.

At trial, Manansala recanted his earlier admission, claiming that he did not understand the contents of Exhibit C and had only signed it to secure his release.
He argued the interrogation and reading of the document’s contents were conducted in English—a language he claimed not to understand.
Additionally, he offered an alternative explanation that a seven-year-old boy, alleged to frequent his house, was responsible for the alterations.

The falsification shifted the meaning of the TVR, suggesting the accused had only one pending case rather than the actual three.
The alteration directly benefited Manansala by reducing the risk of arrest on the grounds of committing a fourth traffic violation, given the established MPD practice of arresting drivers on a fourth offense rather than issuing a TVR.

Whether the lower court erred in sustaining the theory that possession and use of the falsified TVR presumes that the accused, Manansala, is the author of the falsification.
Whether it is legally tenable to convict a person based on such presumptive evidence without more direct proof or credible contradictory testimony.

Whether Manansala’s claim that he did not understand the contents of the confession and his alternative explanation involving a minor can sufficiently rebut the presumption of guilt established by his exclusive possession and use of the altered document.