G.R. No. 9146 - People vs. Rampas

The case involves an appeal from a judgment of the Court of First Instance of the Province of Ambos Camarines.
The defendant, Pedro Rampas, was convicted for presenting a falsified private document as evidence in a civil trial.
The civil case (No. 59) was between Chinaman Agapito Carranceja (complainant) and Pedro Rampas (defendant).

The incident occurred on or about May 16, 1911, during a hearing at the court of the justice of the peace of Talisay, Ambos Camarines.
During the hearing, Rampas introduced into evidence a receipt (Exhibit B) which purportedly showed that Agapito Carranceja was indebted to him for the sum of P500.
The receipt allegedly bore what was claimed to be the genuine signature and seal of Agapito Carranceja.

The prosecution demonstrated that the signature and seal on the receipt were not those of Agapito Carranceja.
It was shown that Pedro Rampas himself had manufactured the characters on the receipt.
The evidence left no doubt that the document was self-made by the accused and that it was intentionally introduced as evidence to mislead the court.

Although it was argued that the document might not exactly fit the description under article 304 in connection with article 300 of the Penal Code because the signature was not perfectly imitated, the trial court found otherwise.
The court held that the elements of intent to imitate and an attempt to do so were clearly present, even if the imitation was not perfect.
The forged signature, while not an exact replica of Agapito Carranceja’s genuine Chinese signature, bore sufficient resemblance — particularly the close imitation of the first character — to establish the accused’s intent to commit the offense.

Based on the evidence and findings, Rampas was convicted of the crime of presenting a falsified private document.
The original sentence imposed on the accused included six months of arresto mayor in the provincial jail, a fine of 1,000 pesetas (with subsidiary imprisonment in case of insolvency), and payment of costs.

Whether the act of presenting a falsified document, which did not perfectly replicate the genuine signature but bore enough resemblance, constitutes the crime of falsification under the Penal Code.
Whether an imperfection in the imitation negates the existence of intent to defraud the court.

Whether the evidence presented by the prosecution was sufficient to prove that Rampas himself manufactured the document.
Whether the resemblance between the forged and genuine signatures met the threshold required to establish a criminal intent to imitate.

Whether the penalty imposed (initially six months of arresto mayor, fine, and additional sanctions) should be modified based on the circumstances of the case.
Whether mitigating factors exist that justify a reduced sentence.