G.R. No. 241164 - Torres vs. Court of Appeals

Petitioner Crizalina B. Torres, then an Intelligence Agent I of the NBI-Western Mindanao Regional Office (NBI-WEMRO) with Salary Grade 10, was charged in six criminal cases for falsification of documents under Article 171 of the RPC.
The charges arose from alleged acts of falsification of Daily Time Records (DTRs) and Applications for Leave allegedly submitted for different periods in 2010 and early 2011.

The petitioner allegedly altered her August 2010 DTR by counterfeiting the signature of NBI-WEMRO Assistant Regional Director Atty. Oscar Embido.
The document was made to appear validated by Embido despite his actual non-involvement.

It is alleged that she falsified her September 2010 DTR to indicate full attendance despite leaving the office on September 21, 2010.
The signature of ARD Oscar L. Embido was falsely imitated to suggest verification of her reported office hours.

The DTR for October 2010 was similarly falsified by making it appear that she reported for work on all days.
The signature of NBI-WEMRO Ex-O Vicente Essex E. Minguez was counterfeited to imply validation by the regional director.

The petitioner is accused of altering the date of her leave application in order to make it appear as if it were filed on September 17, 2010.
The falsified document bears a counterfeit signature of ARD Oscar L. Embido, indicating his alleged approval.

The DTR for November 2010 was also alleged to have been falsified to falsely indicate full attendance.
Again, the signature of Ex-O Vicente Essex E. Minguez was imitated in order to simulate the proofreading by the regional director.

Criminal Case No. 13-300686 (Application for Leave for November 8–December 10, 2010)

Similar to the October application, this document allegedly had its filing date altered from the actual January 18, 2011 to a falsified September 17, 2010.
The document too bore a counterfeit signature of ARD Oscar L. Embido, falsely indicating authorization.

Initiated by a request from then NBI-WEMRO Regional Director Atty. Manuel A. Almendares, an investigation was conducted by the NBI-Internal Affairs Division due to the petitioner’s prolonged absence from work after September 21, 2010.
Investigators obtained multiple versions of the petitioner’s DTRs from the NBI-Personnel Division:

Two DTRs for August 2010 (received on November 3, 2010, and December 23, 2010) both bearing the signature of ARD Oscar Embido.
DTRs for October and November 2010 purportedly containing the signatures of Ex-O Vicente Essex E. Minguez for and on behalf of the regional director, which were later challenged by the alleged signatories.

Acting Administrative Officer George S. Perez testified that the DTRs for October and November were not originally filed with his office.
A comparative handwriting examination by the NBI-Questioned Documents Division showed that the signatures on the disputed DTRs did not match the verified sample signatures of Embido and Minguez.
The Personnel Division certified that no leave applications had been received from the petitioner for the period between September 21, 2010 and December 2010, with actual applications filed only on January 18, 2011.

The petitioner pleaded not guilty at arraignment, and a trial on the merits was subsequently conducted.
The Regional Trial Court (RTC) rendered a decision on October 26, 2016, convicting the petitioner on six counts of falsification of public documents with corresponding penalties for each case.
The petitioner appealed the RTC’s decision, contesting the sufficiency of direct evidence linking her to the falsification and submission of the subject documents.
The Court of Appeals (CA) rendered a decision on February 22, 2018, denying the petitioner’s appeal, upholding the RTC’s findings and ruling that circumstantial evidence was adequate to establish her guilt beyond reasonable doubt.
A subsequent resolution on August 1, 2018 denied any reconsideration, leading the petitioner to file a Petition for Review on Certiorari.

Whether or not the Court of Appeals gravely erred in holding that direct evidence is not a sine qua non requirement for proving the guilt of an accused, thereby permitting the use of circumstantial evidence in this case.

The petitioner argued that no direct evidence was presented to show that she authored or submitted the disputed documents.
She further contended that the absence of eyewitness testimony regarding her submission casts doubt on her guilt.

Whether the totality of circumstantial evidence adequately established, beyond reasonable doubt, that the petitioner, taking advantage of her official position, falsified the DTRs and Applications for Leave.

This includes the demonstration of altered dates and counterfeited signatures which were not consistent with the verified signatures of the alleged officers.
The issue also encompasses whether the procedural lapses in the filing process (e.g., absence of the documents in the designated office) contributed to the evidence against her.

Whether the penalties imposed by the RTC, as affirmed by the CA, are appropriate given the nature of the offense committed by a public officer under Article 171 of the RPC.

The petitioner maintained that the penalties should not be sustained if the evidence was deemed insufficient.
The public respondent contended that the penalty range, invoking the Indeterminate Sentence Law, was correctly applied in view of the established facts.