Case Summary (G.R. No. 74226-27)
Facts of the Case
The registered deed of sale, claiming to be executed by Julio Rizare and Patricia Pampo, was recorded on May 26, 1961, transferring the property to Mizpah R. Reyes. The complainants discovered purported discrepancies regarding this document in June 1983 and subsequently initiated a complaint with the National Bureau of Investigation (N.B.I.) regarding the authenticity of their parents' signatures. The N.B.I. report indicated that while the signature of Julio Rizare was genuine, that of Patricia Pampo was forged.
Legal Proceedings
On October 18, 1984, the Regional Trial Court of Batangas, Branch XIII, Lipa City, received two criminal informations against Mizpah R. Reyes for falsification of public documents. The first case (Criminal Case No. V-1163) involved the forgery of Patricia Pampo's signature, and the second case (Criminal Case No. V-1164) pertained to an untruthful declaration about the accused's civil status.
Before the arraignment, Reyes filed a motion to quash the informations, arguing the prescription of the crimes and lack of jurisdiction due to non-compliance with pre-conciliation requirements. The trial court ruled in favor of Reyes, quashing the informations on grounds of prescription, stating the prescriptive period began with the registration of the document on May 26, 1961.
Court of Appeals Decision
Upon appeal by the People to the Court of Appeals, the appellate court upheld the trial court's order, emphasizing the established principle that registration of a public document serves as constructive notice. It determined that the ten-year prescriptive period commenced on the registration date rather than when the alleged forgery was discovered by the complainants.
Legal Principle on Prescription
The relevant legal provisions are drawn from the Revised Penal Code, specifically Article 172 concerning falsification of public documents, which prescribes a penalty of prision correccional and a fine not exceeding P5,000. Article 90 outlines a ten-year prescriptive period for such offenses, beginning from the date of discovery of the crime, as per Article 91.
Application of Constructive Notice
The determination of prescription hinges on the acknowledgment that once the notarized deed of sale was recorded, it provided constructive notice of its contents to the public. Citing precedents, the Court underscored that individuals are presumed to have knowledge of the information contained within registered documents.
Impact of Decision on Criminal Liability
In this case, the Supreme Cou
...continue readingCase Syllabus (G.R. No. 74226-27)
Background of the Case
- The case revolves around the crime of falsification of a public document, specifically a notarized deed of sale.
- The document in question was registered on May 26, 1961, in the name of the accused, Mizpah R. Reyes, who is the private respondent.
- The complainants, Cristina R. Masikat, Julieta R. Vergara, and Aurora Rizare Vda. de Ebueza, are the children of the deceased owners of the property involved.
- The property was originally owned by spouses Julio Rizare and Patricia Pampo, who have since passed away.
- The complainants alleged that they discovered the falsification in June 1983, prompting their legal action.
Legal Framework
- Falsification of a public document is punishable by prision correccional in its medium and maximum periods, along with a fine not exceeding P5,000.00, as per Article 172 of the Revised Penal Code (RPC).
- The prescriptive period for such a crime is ten (10) years, starting from the date the crime is discovered by the offended party or the authorities, according to Article 90, paragraph 3, and Article 91 of the RPC.
Discovery of the Crime
- The complainants discovered that the property had been transferred to Mizpah R. Reyes under Transfer Certificate of Title (TCT) No. T-9885.
- The deed of sale, executed on May 19, 1961, was found to contain signatures of their parents that were allegedly forged, as well as an untruthful statement regarding Mizpah's marital status.
Legal Proceedings
- Following the discovery, the