G.R. No. 36345 ; November 25, 1932
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. PEDRO MONTANO and WENCESLAO CABAGSANG, defendants-appellants.

FACTS

Defendants-appellants Pedro Montano (Justice of the Peace) and Wenceslao Cabagsang (Chief of Police) of Tanza, Cavite, were convicted of falsification of public documents. The case stemmed from Montano’s delay in conducting a preliminary investigation for a qualified seduction case against Arturo A. Soriano. After an administrative charge was filed against Montano for violating a circular requiring disposition of preliminary investigations within ten days, the defendants falsified official records (police blotter, arrest record, return of warrant, and bail bond) to make it appear Soriano was arrested and posted bail on September 13, 1930, instead of the true date, September 6, 1930. This was done to make Montano’s delay appear compliant with the circular.

ISSUE

Whether the defendants-appellants are guilty of the crime of falsification of public documents.

RULING

Yes. The Supreme Court affirmed the conviction. After a careful review of the evidence, the Court found the evidence of guilt beyond reasonable doubt and rejected the defense of good faith. The alterations were made fraudulently to conceal Montano’s violation of the circular on preliminary investigations. The penalty imposed by the trial court was affirmed. (Note: A concurring opinion recommended executive clemency due to lack of malice and injury, while a dissenting opinion found the proof insufficient for conviction.)

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