Title
People vs. Reodica
Case
G.R. No. 42557
Decision Date
Dec 7, 1935
Municipal treasurer acquitted of falsification charges for certifying payroll; payment date alteration deemed immaterial as salary was legally due.

Case Summary (G.R. No. 170096-97)

Facts of the Case

Lorenzo Reodica, serving as the municipal treasurer of Bacuit in the Province of Palawan, was charged with the falsification of a public document related to the municipal payroll for July 1931. The charge stemmed from accusations that Reodica falsely certified that Cordero rendered services as municipal secretary during the period from July 23 to July 31, 1931, despite Cordero's absence from Bacuit for that timeframe.

Evidence and Procedural Background

The information presented against Reodica included a prepared payroll submitted by the municipal president, which detailed Cordero's supposed services. The payroll was accompanied by a letter from the municipal president authorizing the payment of Cordero's salary for the latter half of July. Furthermore, Cordero was clearly documented as having been granted leave from July 23 to July 31, which directly impacted the allegations against Reodica.

Legal Findings

The court noted that the municipal president, not Reodica, had certified that the services listed in the payroll were rendered. Reodica received the payroll already signed and approved for payment, thus bearing no direct responsibility in the alleged falsification. Although Reodica was accused of certifying the payroll incorrectly, the court found that he had not made any false claims, particularly concerning the actual payment which occurred on July 23, 1931, rather than July 31 as noted.

Ruling

The court concluded that Reodica should not be found guilty of the crime of falsification. The reasoning was based on the understanding that since Cordero had been granted leave during the period in question, the implication was that the salary he received was valid, regardless of payment timing. The alterations made in the payroll document did not impact the truthfulness or legal effects of the document in terms of Cordero’s compensation. In light of this assessment, the prior judgment was reversed, leading to Reodica's a

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