Case Summary (G.R. No. L-31979)
Facts of the Case
Petitioner served Loran Industries for 25 years, reaching the head of accounting and finance and acting as corporate secretary. Following a two-signatory policy adopted by the board on June 19, 2003, she executed a Secretary's Certificate on August 25, 2003, stating that one board member could sign checks. This Certificate was later disputed by the board, leading to allegations of falsification against her.
Legal Proceedings
On March 31, 2005, an Information was filed against petitioner for falsifying the Secretary’s Certificate, claiming it misrepresented the board's actions. The prosecution presented Lorna and Antonio Quisumbing as witnesses, both testifying to the absence of a board meeting or resolution on the Certificate's date. The defense, led by petitioner, relied on testimonies from co-employees who described challenges caused by the two-signatory policy.
Ruling of the MTCC
The Municipal Trial Court in Cities (MTCC) found petitioner guilty of falsification and imposed an indeterminate penalty. The MTCC ruled that the intent to commit the offense was presumed unless proven otherwise and concluded that petitioner’s actions indicated knowledge of her lack of authority to issue the Certificate.
Ruling of the RTC
Petitioner appealed to the Regional Trial Court (RTC), which upheld the MTCC decision in its entirety. It cited that the action undertaken by the petitioner lacked authority, reinforcing that falsification of public documents is based on the preservation of public faith, irrespective of intent to harm a third party.
Ruling of the Court of Appeals
Dissatisfied, petitioner elevated the case to the Court of Appeals, which affirmed the lower court's rulings but increased the fine to P5,000. The appellate court agreed that the presumption of criminal intent was not overcome by the petitioner and emphasized that intent to benefit or prejudice a third party is not required for falsification.
Petition for Review on Certiorari
Petitioner filed a Petition for Review on Certiorari, insisting she acted under Paolo’s instructions and not with criminal intent. She argued that the boards were aware of the checks signed with one signature and often benefi
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Case Background
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the Decision dated March 30, 2012, and the Resolution dated July 15, 2014, from the Court of Appeals (CA) in CA-G.R. CR No. 01042.
- The petitioner, Marilyn Y. Gimenez, was convicted of falsification of a public document as a private individual, under Article 172(1) in relation to Article 171(2) of the Revised Penal Code (RPC).
- The conviction was affirmed with modification, imposing an indeterminate penalty and increasing the fine to P5,000.00.
Parties Involved
- Petitioner: Marilyn Y. Gimenez, a former employee of Loran Industries Incorporated, who held various positions, including corporate secretary.
- Respondents: People of the Philippines and Loran Industries Incorporated, a private corporation engaged in manufacturing furniture.
Facts of the Case
- Loran Industries was incorporated by several individuals, including Antonio and Lorna Quisumbing, and was governed by a Board of Directors.
- Petitioner worked for Loran Industries for 25 years, eventually becoming the head of accounting and finance.
- On June 19, 2003, the Board adopted a two-signatory policy for issuing checks.
- On August 25, 2003, petitioner executed a Secretary's Certificate allowing checks to be issued with only one signatory, allegedly without the Board’s approval.
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