G.R. No. 8025 - People vs Mateo

The case involves an appeal from a judgment of the Court of First Instance of Nueva Ecija.
The defendant, Alejandro R. Mateo, is a priest of the Roman Catholic Church stationed in the town of Aliaga, Nueva Ecija during November 1911, having been in the area for several months prior.
The case arose from a conviction under Section 55 of Act No. 1189, which penalizes the falsification of a cedula (personal tax certificate).

On October 27, 1911, while performing his duties, Mateo was required to execute an affidavit for cashing a check.
As a prerequisite to administering the oath for the affidavit, the public officer requested that Mateo produce his personal cedula for the current year (1911).
Unaware of the necessity, Mateo produced two cedulas – one for 1911 and an older one for 1910.
Upon examination, it was discovered that the 1910 cedula had been altered: the age originally recorded as “23” was changed to “25.”

A complaint was filed alleging that by altering his age on the 1910 cedula, Mateo committed falsification in violation of Section 55 of Act No. 1189.
The prosecution relied on the premise that the alteration resulted in his cedula reflecting an older age, thereby affecting the tax computation.
It was contended that because the cedula for 1910 was altered in 1911, when it was no longer the operative document, the act was still charged as defrauding the internal revenues.

Mateo testified that, prior to being called upon to execute the affidavit, he had not examined his cedulas carefully and was unaware of their contents.
Upon subsequently reading the cedulas, he noticed the age discrepancy and, stricken by fear of potential sanctions, approached the municipal treasurer to have the error corrected.
Mateo admitted that he voluntarily informed the municipal treasurer of his correction and had no intention to defraud the government.
The evidence indicated existing friction between Mateo and certain municipal officials, suggesting that the complaint against him might have been influenced by personal animosity or prior disputes.

The prosecution maintained that the alteration of the cedula, regardless of the absence of criminal intent or pecuniary gain, automatically amounted to falsification under the statute.
It was argued that any change in a cedula—whether material or immaterial, whether correcting an error or fabricating data—could potentially defraud the government.
A key point was the assertion that, had the cedula not been altered, the correct age would have resulted in the payment of a higher cedula tax for a longer period, thereby causing a loss to the government.

The information charged Mateo with altering the 1910 cedula in October 1911 and retaining the altered document with an intent to use it for possible future fraudulent purposes.
The court record quoted the basis of the conviction which included the inference that the altered age directly resulted in a deficit in tax payments.
Additional references were made to precedents and comparative jurisprudence, including decisions from the supreme court of Spain and writings by Viada regarding the alteration of essential elements in a cedula.

Whether the act of altering the age in the 1910 cedula—which by the time of alteration had expired—could legally be said to defraud the government.

Did the alteration cause an actual or potential loss in revenue for the government, considering that only the 1911 cedula was effective when the affidavit was executed?
Whether the alteration, when made to correct the record to reflect Mateo’s true age, constituted a criminal act despite its honest motivation.

Whether the lack of criminal intent or malicious purpose should exonerate Mateo, given that he voluntarily disclosed his correction to the treasurer.
Whether the absence of a material change affecting privileges or immunities dispels the notion of fraudulent intent.

Whether the statute’s broad construction mandates that any alteration—regardless of its effects—automatically causes fraud.
Whether a misrepresentation that does not induce a financial deficit or advantage can be deemed a violation of the law.