G.R. No. 144026 ; June 15, 2006
FERNANDO S. DIZON, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Fernando S. Dizon was charged with Falsification of a Private Document under Article 172 of the Revised Penal Code. The prosecution alleged that in July 1986, Dizon, an officer of First United Construction Corporation (FUCC), prepared and submitted a certification to the Public Estates Authority (PEA) to support FUCC’s bid for a project. The document, dated July 10, 1986, purported to be issued by Titan Construction Corporation, certifying that FUCC had undertaken specific construction projects for Titan. The prosecution presented witnesses who testified that the listed projects were never undertaken by FUCC and that the signature of Titan’s president on the certification was forged.
For the defense, Dizon testified that he requested his father to secure the certification from Titan. His father provided the document, and Dizon, believing it to be genuine, included it in FUCC’s bid submission. He claimed no personal knowledge of its preparation or the forgery of the signature, asserting he only learned of the falsity when the criminal case was filed. The Regional Trial Court convicted Dizon, a decision affirmed by the Court of Appeals, leading to this petition.

ISSUE

Whether the prosecution proved the guilt of the petitioner for the crime of falsification of a private document beyond reasonable doubt.

RULING

The Supreme Court reversed the lower courts’ decisions and acquitted Fernando S. Dizon. The Court emphasized that in criminal cases, the burden of proof lies with the prosecution to establish guilt beyond reasonable doubt. The elements of falsification of a private document under Article 172 in relation to Article 171(4) require that the accused committed any of the acts of falsification, such as making a document appear to have been made by someone who did not actually make it, and that the falsification was committed with intent to cause damage.
The Court found the prosecution’s evidence insufficient. Crucially, there was no direct evidence proving that Dizon himself prepared the forged certification or caused its forgery. The testimony of the prosecution witness, Jose Caneo, was based merely on presumption, not personal knowledge, that Dizon, as the document’s possessor and submitter, must be its author. This presumption alone cannot substitute for the requisite proof beyond reasonable doubt. Dizon’s defense—that he received the document from his father and believed it to be authentic—remained unrebutted. The prosecution failed to establish the essential element of Dizon’s personal participation in the act of falsification. Where the evidence admits two possibilities, one consistent with innocence and another with guilt, the former must prevail. Consequently, Dizon’s acquittal was ordered on the ground of reasonable doubt.