G.R. No. L-9460; April 23, 1957
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. SANTIAGO UY, defendant-appellee.

FACTS

The prosecution filed an information charging Santiago Uy, a field agent of the National Bureau of Investigation (NBI), with the crime of falsification of an official document under Article 171 of the Revised Penal Code. The information alleged that Uy, knowing he was a Chinese citizen born of Chinese parents and therefore not qualified to hold a confidential public office in the Philippine Government, willfully falsified a Personnel Information Sheet of the NBI. He stated therein that he was a naturalized Filipino citizen, a first grade civil service eligible, and had attended the first-year law course at Far Eastern University in 1942, all of which were allegedly false. He executed an affidavit on the last page of the sheet. The purpose of these false statements was to convince the NBI authorities that he was fit and qualified to continue his employment as a field agent and to mislead them into retaining him. The Court of First Instance of Manila dismissed the information on two grounds: (1) the position of an NBI agent was confidential and did not require citizenship or civil service eligibility, making the untruthful statements immaterial to the document’s integrity; and (2) Uy made the statement regarding Filipino citizenship in good faith, believing he was such under the principle of jus soli prevailing at his birth in 1918. The People appealed this order of dismissal.

ISSUE

Whether the facts alleged in the information constitute the crime of falsification of an official document under Article 171 of the Revised Penal Code.

RULING

Yes. The Supreme Court reversed the order of dismissal and remanded the case for further proceedings.
1. The lower court erred in holding the falsities were immaterial. For a motion to quash, the allegations in the information must be taken as true. The information alleged Uy made the false statements “solely to convince the authorities that he was fit and qualified to continue in the employment” and “to mislead the authorities so that he may be retained as field agent.” Precisely because the NBI field agent position was confidential, the appointing authorities had discretion in appointing or retaining agents, and the falsely stated facts (citizenship, civil service eligibility, law course attendance) could properly be considered by them. The prosecution might prove there was a practice or regulation in the NBI making such qualifications important. The Civil Service admits the appointing officer’s right to demand such requirements for confidential positions. Therefore, the false statements could not be declared prima facie immaterial.
2. Regarding the defense that Uy, as part of the existing personnel transferred to the NBI under Republic Act No. 157 , could not be discharged, the Court held this provision must be read in conjunction with the Director’s power to determine the Bureau’s composition and size. The Director could assign Uy to a different role, not necessarily as a field agent. The false statement’s purpose, as alleged, was to induce retention as a field agent, which is a material consideration. Furthermore, the law giving preference to law graduates suggests law students may also enjoy preference, making the false statement about attending first-year law material.
3. The Personnel Information Sheet is an official document, as it was required by the NBI to be filled by its officers for record and information purposes.
4. The alleged violation is under Article 171, paragraph 4 (making untruthful statements in a narration of facts). Uy, a public officer, took advantage of his position by filling up the information sheet himself, which was to be submitted by every NBI officer or employee.
5. The defense of good faith regarding citizenship is a matter for trial and was not admitted by the prosecution. It is noteworthy that Uy stated he was a naturalized citizen, not a natural-born one.
6. The court has jurisdiction, as the crime charged is under Article 171, not a mere falsification of a certificate of merit under Article 174.