Del Rosario vs.

People
Del Rosario was shown by the accused a P1 bill and a P2 billinducing him to believe that the bills
were counterfeitedwhen they were in fact genuine treasury notes. One of thedigits of each bill
was altered to make it appearcounterfeited.Held: The possession of genuine treasury notes of
thePhils, where any of the figures, letters, words or signscontained therein had been erased
and/or altered,
Withknowledge of such erasure/alteration, and with intent touse such notes in enticing another
to advance funds for thepurpose of financing the manufacture of counterfeit notesis punishable
by Art. 168 in relation to Art 169 (1).
People vs. Galano
Galano bought 4 balut eggs with a P1 bill with the wordvictory written on it. The P1 bill had
been withdrawnfrom circulation. It is however redeemable at face its facevalue if presented to
the Central Bank.Held: The forgery committed falls under Art 169(1) wherethe treasury note by
the addition of the word victory wasgiven the appearance of a true and genuine document.
Thisprovision also covers the situation where originally true andgenuine documents have been
withdrawn or demonetizedwere made to appear a true legal tender
Beradio vs. CA
The accused was the Chief of Office, Office of Election registrar who was accused as
havingfalsified her daily time record.
Where non-faithful statement of daily hoursof work in time record has not causeddamages to
the Govt, no crime of falsificationcan accrue. While it is true that a time recordis an official
document, it is not criminallyfalsified if it does not pervert its avowedpurpose as when it does not
cause damage tothe government. It may be different in thecase of a public document with
continuinginterest affecting the public welfare which isnaturally damaged if that document
isfalsified where the truth is necessary for thesafeguard and protection of that generalinterest
Luague vs. CA
Case where the wife signed the payrollwarrant after her husband died.
Absence of criminal intent by petitioner wifewhen she signed her husbands name aspayee.
Absence of damage an element to beconsidered to determine presence of criminalintent. Govt
did not sustain financial loss dueto encashment of checks by the wife.
While it is not meant to imply that if there isno damage there can be no falsification, butthat the
absence of damage is an element tobe considered to determine whether or notthere is criminal
intent.
(Damage is notnecessary in falsification but is intentnecessary?)
Caubang vs. People 1992
Accused was organizing the merger of two stevedoringcompanies. Among the documents
presented and filed withthe SEC for the registration of the company was aStatement of Assets
and Liabilities (SAL) of the company.This had the signature of the treasurer; but this signaturewas
forged.HELD: Accused guilty of falsification of public documents.In the absence of contrary proof,
the accused who filed allthe documents with the SEC, is presumed to have also filedthe forged
SAL. And thus since his possession of the forgedinstrument is presumed, it is also presumed from
this factthat he is the forger of the document.It is immaterial that the entries in the SAL were
true, theimportant thing is that the signature of the treasurer wasforged. What is punished in this
crime is the violation of the faith in public documents and the destruction of thetruth in making it
appear that a person did something whenin fact he did not; damage is not essential.
People vs. Romualdez
Romualdez, the secretary of Justice Romualdez, changedthe grade of bar examinee, Mabunay, to
enable him toreach the required average to pass the bar. She claimedshe had been given the
authority to do so.HELD: The acts of falsification are: (1) making alterationson genuine
documents (2) making it appear that thecorrectors had participated in blotting out the grades
andwriting out new and increased grades opposite their initialsand (3) attributing to the
correctors statements other thanthose in fact made by them.

Beradio vs. CA
Beradio is the lawyer and election registrar accused of falsifying her daily time record, a public
document. Herdaily time record shows she was at the office 8am-5pmwhen in fact she went to
court.HELD: Beradio belongs to a class of officers who areexempt from keeping and submitting
daily time records. Nocriminal intent to commit falsification can be imputed toher when she
submits her time record not as a legalobligation but as a matter of practice. The entries shemade
contain a color of truth and no damage was caused tothe govt or a third party.
Luague vs. CA
Luague, a widow, signed her husbands name on the salarychecks with the knowledge of her
deceased husbandssupervisor. She encashed the same and use it to pay debtsincurred for the
illness and death of her husband.HELD: There was no estafa thru falsification of acommercial
document. No damage was incurred against thegovernment as the deceased employee deserved
the salaryhis wife availed of. Even if there was falsification when shesigned for her husband, this
was done with the knowledgeof her deceased husbands supervisor that the husband wasindeed
dead. (Reezas dad in the RTC ruled otherwise)
Cabigas vs. People
Cabigas, a securities custodian of Landbank, was convictedof falsification when he changed the
entry of the figure of treasury bills from 1539 to 1533 pieces in the Daily Reportof
Securities/Documents under Custody (DR SDUC) for thepurpose of hiding the loss of 6 treasury
bills in his custody.HELD: SC acquitted him since the elements of Art 171(4)were not present. The
correction of the figure from 1539 to1533 pieces to conform to the actual pieces of treasurynotes
in custody is not falsification since it was made tospeak the truth. Also, the DR/SDUC is a form
purely devisedand adopted by Cabigas and was never required thus hewas not legally obligated
to disclose or reveal the truth inthat document. In the absence of legal obligation, therecan be no
falsification.
People vs. Sendaydiego
Sendaydiego, a provincial treasurer, used 6 forgedprovincial vouchers to embezzle from the road
and bridgefund. TC convicted them of malversation thru falsificationof public document.HELD: SC
held that the crimes committed are separatecrimes of malversation and falsification because in
the 6vouchers, the falsification was used to conceal themalversation. Each falsification and
malversationconstituted independent offenses which must be punishedseparately.
Siquian vs. People
Siquian, a municipal mayor, appointed a clerk and signedthe latters appointment papers which
stated that therewas such a position available and that funds for this
position was available. However, no such position and fundswere in existence. The mayor knew
that the MunicipalCouncil failed to enact a new budget and has adopted theprevious years
budget.HELD: SC held Mayor liable under Art 171(4), when he madean untruthful statement in a
narration of facts contained inthe certification which he issued in connection with
theappointment of the clerk. The existence of a wrongfulintent to injure a third person is not
necessary when thefalsified document is a public document. It is because theprincipal thing
punished is the violation of public faith andthe destruction of truth proclaimed therein.
People vs. Villalon
Carrera brothers were co-owners of a parcel of land. Apower of attorney was executed
authorizing de Guzman tomortgage one brothers half. De Guzman used the power of attorney to
obtain a loan from the mortgagee bank. Loanwas unpaid, bank foreclosed the mortgage and sold
land toSerafia who filed ejectment suit against the brothers.HELD: The crime committed was
estafa thru falsification of public document. The falsification of public document maybe a means
to commit estafa because before the falsifieddocument is actually used to defraud another, the
crime of falsification is already consummated and damage or intentto cause damage is not an
element of falsification. Thedamage to another is caused by the commission of estafa.

People vs. Dava

Case where Dava acquired a falsified driverslicense after his previous license wasconfiscated
due to a felony he committed.
Drivers license a public document.
The drivers license being a public document,proof of the fourth element of damage causedto
another person or at least an intent tocause such damage has become immaterial.
In falsification of public or official documents,the principal thing being punished is theviolation
of the public faith and thedestruction of the truth proclaimed therein.