GR 226590; (April, 2018) (Digest)
G.R. No. 226590 APRIL 23, 2018
SHIRLEY T. LIM, MARY T. LIMLEON and JIMMY T. LIM, Petitioners vs PEOPLE OF THE PHILIPPINES, Respondent
FACTS
Petitioners, siblings and officers of Pentel Merchandising Co., Inc., were charged with falsification of a public document. The prosecution alleged that they falsified a Secretary’s Certificate dated February 29, 2000, which contained a Board Resolution authorizing the sale of a corporate property. The document bore the signature of their father, Quintin C. Lim, a purported corporate officer. Quintin, however, had died on September 16, 1996, over three years before the document’s date. Using this falsified certificate, petitioner Jimmy Lim executed a Deed of Absolute Sale conveying the property to the Spouses Lee. The petitioners did not present any evidence during trial, believing the prosecution’s case was weak.
The Metropolitan Trial Court (MeTC) convicted the petitioners, a ruling affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA). The courts found that the prosecution established the elements of falsification under Article 172 of the Revised Penal Code. The petitioners appealed to the Supreme Court, arguing their conviction was based solely on circumstantial evidence and that the crime had already prescribed.
ISSUE
Whether the petitioners are guilty beyond reasonable doubt of the crime of falsification of a public document and whether the crime had prescribed.
RULING
The Supreme Court denied the petition and affirmed the petitioners’ conviction. On the issue of prescription, the Court held that the crime prescribes in ten years from its commission. The Information was filed in 2011, concerning acts in March 2000, thus the crime had not yet prescribed. On the merits, the Court found all elements of falsification by a private individual under Article 172 present. The Secretary’s Certificate, once notarized, became a public document. The petitioners made it appear that their deceased father participated in the corporate resolution, a falsehood they knew and from which they benefited by facilitating the sale. Their defense of relying on circumstantial evidence failed, as the prosecution’s evidence—the death certificate, the falsified document, and the subsequent sale—formed an unbroken chain leading to a fair conclusion of their guilt. Their failure to present contrary evidence further weakened their position. The penalty imposed by the CA was affirmed.