G.R. No. 3195
EN BANC January 24, 1907

FACTS
– Andres Quiroga was convicted by the Court of First Instance (Manila) of “acusación o denuncia falsa” under Art. 326‑327, Penal Code, and sentenced to 1 yr 9 mo prisión correccional.
– The alleged false accusation: on 20 Nov 1905 Quiroga claimed that Exequiel Madelo had stolen his gold coin (₱40). Quiroga reported the accusation to a police officer, who arrested Madelo. Madelo was tried before the municipal court on 24 Nov 1905 and acquitted for lack of evidence.
– The municipal judge ordered Quiroga to be prosecuted for false accusation. Quiroga filed a demurrer before the Court of First Instance, arguing that the complaint did not allege facts constituting the offense under Art. 326. The demurrer was overruled and Quiroga was convicted.

ISSUE
Whether a false accusation made to a police officer, who is not an “administrative or judicial officer” as meant in Art. 326 of the Penal Code, satisfies the element of “falsely imputing… before an administrative or judicial official” necessary to constitute the crime of “acusación o denuncia falsa.”

RULING
– The Supreme Court held that a police officer is not an “administrative or judicial officer” within the meaning of Art. 326. (Citing Viada, vol. 2, p. 476.)
– Consequently, a false accusation directed to a policeman does not meet the statutory requirement that the false imputation be made before an official who is obliged to investigate or punish the alleged crime.
– The conviction was therefore reversed and Quiroga was acquitted with costs awarded to both parties de officio. The case was remanded to the Court of First Instance for execution of the acquittal.

Key Takeaway
Under Art. 326, “acusación o denuncia falsa” applies only when the false allegation is presented to a proper administrative or judicial authority vested with the duty to act; a police officer does not fall within this category, and thus liability under this provision does not arise from complaints made to police.