G.R. No. 167671 September 3, 2008
RICARDO S. SANTOS, JR., petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Ricardo S. Santos, Jr., a disbursing officer of the Bureau of Lands, was charged with malversation through falsification of public documents in four separate cases. After trial, the Court of First Instance found him guilty. On appeal to the Court of Appeals, all his co-accused died, leaving him as the sole appellant. The CA modified the trial court’s decision, acquitting Santos in three cases but convicting him in Criminal Case No. Q-9787 for falsification of a public document under Article 172(1) in relation to Article 171(2) of the Revised Penal Code.
The conviction stemmed from the falsification of a travel expense voucher (Exhibit AA-1). The CA, affirming the trial court’s findings, held Santos guilty as a principal by inducement. It relied on the testimony of state witness Henry Cruz, who stated that Santos induced him to sign the voucher with a promise of a share in the proceeds, even though Cruz was not entitled to such a claim. Santos contested this, arguing the CA inconsistently credited Cruz’s testimony for one voucher but not for others.

ISSUE

Whether the Court of Appeals erred in convicting petitioner of falsification of a public document as a principal by inducement based on the testimony of Henry Cruz.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best left to the trial court, which directly observes demeanor, and such findings are accorded great weight, especially when affirmed by the appellate court. The CA’s acquittal in the three other cases did not mean Cruz lied; it merely found his testimony insufficient for conviction in those instances, whereas for Exhibit AA-1, his testimony was deemed credible and sufficient.
The Court found all elements of falsification by a private individual or a public officer not taking advantage of his official position under Article 172(1) present. Santos, a public officer, committed the act of falsification enumerated in Article 171(2) by causing it to appear that Cruz participated in an act when he did not. His function as a disbursing officer did not include preparing vouchers, but he intervened. The inducement was established through his promise of a share in the proceeds, which constitutes inducement by offering a promise, regardless of any supervisory power over Cruz. The document was undisputedly public. Thus, his conviction as a principal by inducement was proper.