EstelaRomualdez Case, 57 Phil 148

Facts:
The accused Estela Romualdez and Luis Mabuhay were charged with the crime of
falsification of public and official documents.
The accused Estela Romualdez was the secretary of Honorable Norberto Romualdez, one
of the Justices of the Supreme Court. The latter was then the Head of the Bar Examination
Committee. Because of such functions, she had under her care the computations and other papers
and documents for the admission of the candidate to the Bar held in the month of August and
September 1926. At that time, aside from the Committee of Bar Examiners, a Committee of
Correctors was also appointed. The work of the Committee of Bar Examiners was to prepare the
test questions on their respective subjects and a memorandum of authorities and legal provisions
as well as jurisprudence as sources of the questions. The work of reviewing and grading the test
booklets were entrusted to the Committee of Correctors who were furnished the notes and set of
rules.
The information filed alleged that the accused Estela Romualdez and Luis Mabunay
conspired together and erased the grade of 58% given by the correctors to the composition in
Remedial Law and replaced it and, instead, wrote 64%. She also crossed out and replaced the
grade of the latter in Civil law from 63% and wrote 75%. With the said changes, Mabunay
obtained an average of 75%. In the said examination, the Supreme Court considered the Grade of
70% as 75% as passing average.
The accused Estela Romualdez contended that she has the authority to make such
alteration, both in her capacity as the private secretary of the Chairman of the Examination
Committee and as the correctors and at the same time supervisor of the Correctors. The
authority was given by the then Chairman himself, Justice Norberto Romualdez. She further
contended that she did not know Luis Mabuhay and the first time he saw him was on the first day
of the trial. Furthermore, she alleged that her revision of the compositions of her co-accused was
due only and solely to a happy coincidence.

Issues:
1. Whether Estela Romualdez was guilty of Falsification; and
2. Whether Estela Romualdez was authorized to make the alterations.

Held:
1. Yes. The acts of the accused Estela Romualdez were covered by paragraphs 2, 3 and 6 of
article 300 of the Penal Code. She made the alterations in the grades given by the "correctors" in
the papers in question in such a way as to make it appear that said "correctors" had participated
therein, because she blotted out the grades of the "correctors" and wrote new and increased
grades opposite their initials, without indicating by her own initials that she had made the
alterations. She, in that way, attributed to the "correctors" statements other than those in fact
made by them.
2. No. If it be admitted that the accused E. R. was given the authority which she claims to
have received, nevertheless she was not authorized to change the grades now in question because
when she made the changes she already knew that the papers belonged to her co-accused.
The Chairman of the Bar Examination Committee was presumed to have discharged his
duties in accordance with the law and it was inconceivable that he would without any warrant of
law give or attempt to give the accused Estela Romualdez the unlimited authority which she
claimed to have received, thereby enabling her to alter at will any grade on any paper, without
making any record thereof or any report to anybody. The mere statement of such claim showed
that it was preposterous.