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G.R. No.

L-16806, December 22, 1961

SERGIO DEL ROSARIO, PETITIONER, VS. THE PEOPLE OF THE PHILIPPINES,


RESPONDENT

Accused of counterfeiting Philippine treasury notes, Sergio del Rosario, Alfonso Araneta and
Benedicto del Pilar were convicted by the Court of First Instance of Davao of illegal possession of
said forged treasury notes and sentenced to an indeterminate penalty ranging from 8 years and 1 day
to 10 years and 1 day of prision mayor, and to pay a fine of P5,000, without subsidiary imprisonment
in case of insolvency, as well as a proportionate part of the costs.
Complainant alleged that he was induced to believe that the accused manufactured the counterfeited
paper money even though they were genuine notes which one of the digits are altered and changed.
Issue: WON the possession of the altered notes is a violation under Article 168 of the RPC
Held: Yes, It is clear from these provisions that the possession of genuine treasury notes of the
Philippines any of the figures, letters, words or signs contained" in which had been erased and/or
altered, with knowledge of such erasure and alteration, and with the intent to use such notes, as they
were used by petitioner herein and his co-defendants in the manner adverted to above, is punishable
under said Article 168, in relation to Article 166, subdivision (1), of the Revised Penal Code (U.S. vs.
Gardner, 3 Phil., 398; U.S. vs. Solito, 36 Phil., 785).
G. R. No. 31012, September 10, 1932

THE PEOPLE OF THE PHILIPPINE ISLANDS, PLAINTIFF AND APPELLEE, VS.


ESTELA ROMUALDEZ AND LUIS MABUNAY, DEFENDANTS AND APPELLANTS.

Estelita Romualdez altered the grades of Luis Mabunayin two of his bar examination booklets in
order for him to pass the bar examination. Court found Romualdez guilty as principal of the crime
of falsification on public documents under Article 300 (now 171) while Mabunay as a co-conspirator
or co principal under Art 301 (now 172)
Issue: WON the booklets are considered as public documents
Held: Yes, It is also contended that the examination papers which the defendant Estela Romualdez
altered were not public or official documents. That contention is likewise without merit. As stated by
her attorneys, the examination of candidates for admission to the bar is a judicial function. It cannot
therefore be maintained with any show of reason that the papers submitted by the candidates in the
course of the examination were not public and official documents, or that the alteration, under the
circumstances alleged in the information, of the grades given to such papers by the "correctors" was
not a crime. (In re Del Rosario, 52 Phil., 399, where this court refers to the falsification of his
examination papers as "the falsification of public documents"; People vs. Castro and Doe, 54 Phil.,
41, where the conviction of Castro for the falsification of his examination papers was affirmed.)
G.R. Nos. L-55683 & L-55903-04, February 22, 1982

PILAR S. LUAGUE, PETITIONER, VS. THE HONORABLE COURT OF APPEALS


AND PEOPLE OF THE PHILIPPINES, RESPONDENTS.

Pilar Luage, widow of Iluminado encasched and endorsed the treasury warrants issued by the
government representing the unpaid salary of the latter after his death. The said warrants were used
for the unpaid hospital bills, medication and burial expenses of Iluminado. Petitioner herein was
convicted of falsification of commercial documents which the CA affirmed.

Issue: WON there was falsification commited.

Held Yes, The Court of Appeals did not reject the petitioner's version, except in respect of the date
when the first paycheck was delivered. In affirming the decision of the trial court, the Court of
Appeals followed the simplistic procedure of applying literally the letter of the law, namely: there
was falsification because the petitioner "signed her husband's name in indorsing the treasury
warrants in question." The Court of Appeals failed to take into account the following facts: That the
petitioner signed her husband's name to the checks because they were delivered to her by no less
than her husband's district supervisor long after the husband's death which was known to the
supervisor; that she used the proceeds of the checks to pay for the expenses of her husband's last
illness and his burial; and that she believed that she was entitled to the money as an advance
payment for her husband's vacation and sick leave credits the money value of which exceeded the
value of the checks. In the light of these circumstances, We cannot ascribe criminal intent to the
petitioner. We sustain her claim that she acted in good faith.

During the hearing, it was brought out that the government did not sustain any financial loss due to
the encashment of the checks because the petitioner's husband had accumulated vacation and sick
leaves the money value of which exceeded the value of the three paychecks and the value of the
checks was simply deducted from the money value of the leaves. This explains why the petitioner
was not convicted of estafa but of falsification only. While we do not mean to imply that if there is
no damage there can be no falsification, We do say that the absence of damage is an element to be
considered to determine whether or not there is criminal intent.