G.R. No. 2655
THE UNITED STATES, plaintiff-appellee, vs. MODESTO ANGELES, defendant-appellant.

FACTS:
The defendant, Modesto Angeles, was charged with manufacturing a seal imitating the official seal of the Municipality of Lipa, Batangas. He intended to use this counterfeit seal to falsify certificates for the transfer of livestock. The lower court convicted him under the Penal Code, but the case was elevated on appeal to review the propriety of the penalty imposed.

ISSUE:
Whether the defendant’s act of manufacturing a counterfeit municipal seal for falsifying documents constitutes a violation of Article 312 of the Penal Code, and what is the appropriate penalty for such offense.

RULING:
The Supreme Court ruled that:
1. The evidence sufficiently proved that Angeles violated Article 312 of the Penal Code by fabricating a counterfeit seal of the Municipality of Lipa to facilitate falsification of documents.
2. Following the precedent in United States v. Florentino Sayson (4 Off. Gaz., 572), the falsification of such documents falls under Article 311 (not Articles 300 or 301), thus limiting the penalty to the grade immediately inferior to arresto mayor, which is a fine.
3. The lower court’s judgment was reversed. Angeles was instead sentenced to pay a fine of 200 pesos, with subsidiary imprisonment not exceeding one month if the fine remained unpaid.

The decision was unanimously affirmed, with Chief Justice Arellano and Justices Torres, Mapa, Carson, and Tracey concurring.

(Judgment to be entered after ten days, with records remanded to the trial court for execution.)