G.R. No. L-9146; November 26, 1913

FACTS:
On or about May 16, 1911, during the trial of Civil Case No. 59 in the justice of the peace court of Talisay, Ambos Camarines (between Agapito Carranceja, plaintiff, and Pedro Rampas, defendant), the accused Pedro Rampas presented a receipt (Exhibit B) as evidence. The receipt purported to show that Carranceja was indebted to Rampas for P500 and bore what appeared to be Carranceja’s signature and seal. The prosecution established that the signature and seal were not genuine and that Rampas himself had fabricated the document. The Court of First Instance of Ambos Camarines convicted Rampas of presenting a falsified private document as evidence and sentenced him to six months of arresto mayor, a fine of 1,000 pesetas, with subsidiary imprisonment in case of insolvency, and costs.

ISSUE:
Whether the accused can be convicted of falsification of a private document under Articles 304 and 300 of the Penal Code, given that the signature on the document was not a perfect imitation of the genuine signature.

RULING:
Yes, the conviction is proper but the penalty must be modified. The Court held that for the crime of falsification of a private document to exist, it is not necessary that the imitation of a signature be perfect or sufficient to deceive an expert. It is sufficient that there was an intent to imitate, an attempt to imitate, and that the forged signature bears some resemblance to the genuine one. In this case, the evidence showed Rampas attempted to imitate Carranceja’s Chinese-character signature. Although the accused was an ignorant Filipino unfamiliar with Chinese script, the first character of the forged signature closely resembled the genuine one, and the overall signatures bore sufficient resemblance to establish criminal intent and attempt.

The penalty imposed by the trial court was modified. Applying Article 305 of the Penal Code, the Supreme Court sentenced the accused to four months of arresto mayor. The judgment was affirmed in all other respects, with costs against the appellant.