G.R. No. 5036 - People vs. Maleza

On May 31, 1906, Luciano Maleza, serving as treasurer of the municipality of Sevilla in the Province of Bohol, certified an account.
The account, dated similarly, indicated payments made to carpenters and day laborers for work on the municipal building during 1903 and 1904, as well as for packages of nails used in construction.
The total amount stated in the account was P249.35, which had been approved by a resolution of the municipal council.
Maleza certified the authenticity of the document by affirming that the services rendered were necessary for the public interest and that the purchased articles had been duly recorded in the municipal register.

Despite the certification, it was later discovered that Maleza’s statement contained false information concerning the purpose of the funds.
Specifically, though the document stated that the money was intended to pay the carpenters, it was actually drawn and used to pay Luciano Maleza himself.
Maleza received the money as a result of being commissioned by P. Cayetano Bastes to collect and receive a loan granted to the municipal president and treasurer of Sevilla in 1903.

Gabriel Adlaon’s signature appeared at the foot of the document, which misleadingly indicated that he had received the payment corresponding to a previous account balance.
In truth, Adlaon neither received the money nor was it actually disbursed for the work purportedly done by the carpenters.

Based on the discrepancies and misstatements, the provincial fiscal filed a complaint charging Maleza and Adlaon with the crime of falsification of a public document by reason of reckless negligence.
The complaint was grounded on the allegation that both individuals either misrepresented or negligently failed to state the truth concerning the transaction documented.

The facts alleged did not, in themselves, constitute a crime.
The complaint was not properly drawn in accordance with the prescribed legal format.
Even if the facts did constitute a crime, such filing would simultaneously charge two crimes within a single complaint.

On October 7, the lower court sustained the demurrer, finding that the allegations did not establish a crime as, in the view of the trial judge, no such offense of falsification by reckless negligence existed under the law.

Whether the actions of Luciano Maleza and Gabriel Adlaon, as alleged in the complaint, indeed constitute the crime of falsification of a public document by reason of reckless negligence.
Whether the misrepresentation in the public document, despite lacking malice, is punishable under the provisions for acts executed through negligence as stipulated in the Penal Code.

Whether the demurrer raised by the defense, arguing that the complaint was improperly drafted and inadvertently charged dual offenses, was tenable under the prevailing legal standards.