GR 34061; (October, 1931) (Digest)
G.R. No. 34061 ; October 28, 1931
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. FELIPE N. CONCEPCION, defendant-appellant.
FACTS
The accused, Felipe N. Concepcion, was a deputy clerk of the Court of First Instance of Manila. In criminal case No. 36516 (People vs. Victoriano Mata), the accused allegedly told Mata he could arrange a guilty plea and a fine. After Mata was sentenced to a P200 fine, the accused collected partial payments from Mata totaling P49. On the cover of the criminal record, after the printed words “date of commitment,” the accused wrote “6/28/28,” indicating Mata was committed to prison on June 28, 1928, when in fact Mata remained at large. This false entry misled the court into believing Mata was serving subsidiary imprisonment, delaying collection of the fine. The accused was convicted of falsification of a public document.
ISSUE
1. Whether the trial court erred in crediting the testimony of Victoriano Mata.
2. Whether the cover of the criminal case record is a public document.
3. Whether writing the false date of commitment constitutes the crime of falsification of a public document under Article 300 of the Penal Code.
RULING
1. No error in crediting Mata’s testimony. The apparent contradiction between his affidavit and court testimony was explained: the affidavit was prepared by the accused, who implored Mata to sign it. The trial court’s assessment of credibility stands.
2. The cover is a public document. Once filled out by a court official and attached to the record, it becomes an integral part of the record. It contains essential data on case proceedings, relied upon by the court and its officials for daily workflow.
3. The act constitutes falsification. Writing the false date “6/28/28” altered the document’s meaning, making it appear Mata was imprisoned when he was not. This falsehood affected the record’s integrity and impeded the court’s ability to collect the fine. The accused’s claim that he forgot to erase the date due to press of work is belied by his collection of partial payments from Mata.
The judgment of conviction is affirmed.
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