Case Digest (G.R. No. 167671)
Facts:
Ricardo S. Santos, Jr. v. People of the Philippines, G.R. No. 167671, September 03, 2008, Supreme Court First Division, Corona, J., writing for the Court. Petitioner Ricardo S. Santos, Jr. (hereafter petitioner) challenged the July 26, 2004 decision and April 7, 2005 resolution of the Court of Appeals (Sixth Division, penned by Associate Justice Perlita J. Tria-Tirona) affirming in part his conviction for falsification of a public document.On October 8, 1969, four separate informations for malversation through falsification of public documents were filed in the Court of First Instance (CFI) of Rizal, Branch V, Quezon City against petitioner and nine co-accused. Those cases were docketed as Criminal Case Nos. Q-9783, Q-9784, Q-9787 and Q-9788 and concerned travel expense vouchers and related treasury warrants issued in the names of various persons. After trial, the CFI convicted petitioner and one co-accused (Pedro Velasco) of the complex crime of malversation through falsification under Articles 217 and 171 of the Revised Penal Code (RPC), while other accused were acquitted or dismissed on demurrer to evidence; Henry Cruz, one of the accused, became a state witness.
All convicted parties appealed to the Court of Appeals. During the appeal all of petitioner’s co-accused except him died. The CA modified the CFI decision: it acquitted petitioner in Criminal Case Nos. Q-9783, Q-9784 and Q-9788, but found him guilty in Criminal Case No. Q-9787 of falsification of a public document under Article 172(1) in relation to Article 171(2) of the RPC, holding him a principal by inducement based largely on the testimony of state witness Henry Cruz that petitioner induced Cruz to sign the travel expense voucher (Exhibit AA-1) in exchange for a share of the proceeds.
Petitioner brought this Rule 45 petition for review on certiorari, arguing among other points that the CA improperly credited Cruz’s testimony with respect to Exhibit AA-1 but discredited h...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in its credibility determinations and in sustaining petitioner’s conviction where the trial court was the primary trier of facts?
- Did the evidence satisfy the elements of falsification of a public document under Article 172(1) in relation to Article 171(2) of the Revised Penal Code, and was petitioner properly hel...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)