G.R. No. 31013 , September 24, 1929
PEOPLE OF THE PHILIPPINE ISLANDS vs. CIRILO K. ALAFRIZ

FACTS

The accused, Cirilo K. Alafriz, admitted to receiving forged bank notes (Exhibit B) from Pablo Nera with the agreement to sell them at half their face value, retaining one-third of the proceeds for himself. He then delivered these false notes to Paulino Pichay to be negotiated. Alafriz acknowledged that the notes were counterfeit and acted with fraudulent intent. He was prosecuted for violating Act No. 1754 , which prohibits forging and uttering false obligations or securities of the United States or the Philippine Islands.

ISSUE

Whether the accused violated Act No. 1754 by both possessing and uttering the forged bank notes, and whether such notes fall within the scope of “obligations and securities” as defined under the Act.

RULING

Yes. The Supreme Court affirmed the lower court’s judgment, finding the accused guilty of violating both Section 4 (possession) and Section 2 (uttering) of Act No. 1754 . The false bank notes were held to be included under the Act’s definition of “obligations and securities,” particularly under the general clause covering “other representatives of value.” The Court found no error in the conviction and upheld the penalty of ten years’ imprisonment, a ₱1,000 fine, costs, and the destruction of the forged notes.