GR 241164; (August, 2019) (Digest)
G.R. No. 241164 , August 14, 2019
Crizalina B. Torres, Petitioner, vs. The Honorable Court of Appeals and The People of the Philippines, Respondents.
FACTS
Petitioner Crizalina B. Torres, an Intelligence Agent I of the NBI-Western Mindanao Regional Office, was charged with six counts of Falsification of Public Documents under Article 171 of the Revised Penal Code. The Informations alleged that, in relation to her office, she falsified her Daily Time Records for August, September, October, and November 2010, as well as an Application for Leave. The falsifications consisted of making it appear that she reported for work on days she was absent after September 21, 2010, and by counterfeiting the signatures of her superiors, Assistant Regional Director Oscar L. Embido and Executive Officer Vicente Essex E. Minguez, to make it seem they verified her DTRs and approved her leave. She was convicted by the Regional Trial Court, and the Court of Appeals affirmed the conviction.
ISSUE
Whether the Court of Appeals erred in affirming petitioner’s conviction for the crime of Falsification of Public Documents.
RULING
The Supreme Court denied the petition and affirmed the CA’s ruling. The legal logic rests on the established elements of falsification under Article 171, which require that the offender is a public officer, employee, or notary public; that he or she takes advantage of his or her official position; and that he or she falsifies a document by committing any of the acts enumerated, such as counterfeiting a signature or making untruthful statements. The Court found all elements present. As a public officer, petitioner took advantage of her position by falsifying her DTRs and leave application, official documents directly connected to her employment and compensation. The act of counterfeiting her superiors’ signatures and falsely reporting her attendance constituted the specific acts of falsification defined by law.
The Court emphasized that factual findings of the trial court, affirmed by the CA, are generally binding. The evidence conclusively showed petitioner ceased reporting for work after September 21, 2010, yet her subsequent DTRs indicated full attendance, supported by forged verifications. Her defense of denial could not overcome the positive and categorical testimonies of the signatories that their signatures were falsified and that they did not verify the documents. The penalties imposed—within the range of prision mayor for the maximum and applying the Indeterminate Sentence Law for the minimum—were correctly applied. Thus, no reversible error was committed in upholding her conviction.