Case Summary (G.R. No. 111962-72)
Background of the Accusation
The prosecution charged Gamido with forging the President's signature on various documents, including appointments and memoranda purportedly related to a non-existent agency known as the Presidential Regional Assistant Monitoring Services (PRAMS). Gamido claimed he had been appointed by President Marcos and presented the disputed documents as legitimate. However, a memorandum issued by Executive Assistant Juan C. Tuvera declared PRAMS non-existent, which formed the basis of the prosecution's case.
Prosecution's Evidence
During the trial, the prosecution relied on the testimony of Melquiades T. de la Cruz, the Director of the Malacanang Records Office, who asserted that the documents in question had no records in their office, suggesting they could be forgeries. The prosecution aimed to demonstrate that the documents did not originate from genuine sources and were thus fraudulent.
Defense Arguments
Gamido's defense centered on the argument that the absence of the documents in the Malacanang Records Office did not necessarily indicate forgery. He contended that the witness failed to establish that the signatures were indeed forged and that no handwriting expert was presented to substantiate the claims of forgery. Additionally, Gamido argued that the unusual formatting and language of the documents did not constitute forgery because they purportedly could not deceive a reasonable person.
Ruling of the Regional Trial Court
The Regional Trial Court found Gamido guilty of forgery on all eleven counts, affirming that the documents were indeed non-existent and the signatures forged. The court emphasized that the testimony of the prosecution witness was credible, drawing on the presumption that the possessor of a forged document is typically deemed its forger. The court’s decision highlighted the implausibility of Gamido's assertions and underscored the fraudulent nature of the submitted documents.
Appeal and Court of Appeals' Decision
On appeal, the Court of Appeals modified the sentence but affirmed the trial court’s ruling, rejecting Gamido's arguments about the credibility of the evidence and the competence of the witness. The appellate
...continue readingCase Syllabus (G.R. No. 111962-72)
Case Overview
- The case involves Maximino B. Gamido, the petitioner, who was convicted by the Regional Trial Court (RTC) on eleven counts of forgery, specifically for forging the signature of the President of the Philippines.
- The case was reviewed by the Court of Appeals, which affirmed the RTC’s decision with modifications regarding the sentencing.
Background of the Case
- Petitioner Maximino B. Gamido was accused of forging the signature of then President Ferdinand E. Marcos on various official documents, falsely representing them as genuine.
- The documents in question include special appointments, memoranda, and executive orders, all purportedly signed by President Marcos.
Charges
- The charges were based on Article 161 of the Revised Penal Code, which penalizes counterfeiting the seal of the Government or forging the signature of the Chief Executive.
- The eleven specific cases included appointments and memoranda dated between 1983 and 1985.
Evidence Presented
- On March 25, 1985, a memorandum was issued declaring the non-existence of the Presidential Regional Assistant Monitoring Services (PRAMS), which was allegedly headed by Gamido.
- The investigation revealed that the documents presented by Gamido were not on file in the Malacanang Records Office, and a key witness testified that the signatures did not belong to President Marcos.
Trial Court Findings
- The