G.R. No. 2829 (September 19, 1906)
THE UNITED STATES, Plaintiff-Appellee, vs. PIO CASTILLO, Defendant-Appellant.

FACTS:
1. On December 2, 1905, Pio Castillo presented a forged check for ₱56 (payable to bearer) to Chinese merchant Lim Ponso, purportedly drawn by James J. Watkins, the sheriff of Iloilo.
2. The check was paid to Castillo, but Watkins’ signature was forged, and the checkbook had been stolen from Watkins’ office between December 12, 1903.
3. Castillo, a clerk in Watkins’ office, was the last person in the office on December 1 and had access to the checkbook.
4. Castillo denied involvement, claiming he never saw the check, was not at Lim Ponso’s establishment, and did not receive the money. However, prosecution witnesses disproved his claims.

ISSUE:
1. Whether the utterance (use) of a forged check, combined with circumstantial evidence, sufficiently proves Castillo’s guilt for falsification of a mercantile document under Article 302 of the Penal Code.
2. Whether the information filed was defective for allegedly charging Castillo as both principal and accessory.

RULING:
1. Guilt Established:
– The Supreme Court held that Castillo’s possession and use of the forged check, alongside his opportunity to commit the crime and false testimony, constituted strong evidence that he either forged the check or caused it to be forged.
– The Court reversed the trial court’s ruling (which convicted him only of “knowingly using” the document) and found him guilty of falsification.

2. Penalty:
– Due to Castillo’s age (between 1518 years old), the Court imposed the penalty immediately inferior to the prescribed punishment: 4 years of presidio correccional, plus indemnification of ₱56 to the victim.

3. Procedural Issue:
– The Court dismissed Castillo’s claim that the information was defective, noting that no objection was raised at trial and the allegation of receiving proceeds was included to establish civil liability, not to charge him as an accessory.

Disposition: Judgment reversed; Castillo convicted of falsification. Affirmed with modifications.

(Arellano, C.J., Torres, Johnson, Willard, and Tracey, JJ., concurred.)

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Key Doctrine:
– The utterance of a forged document, when unexplained, is strong circumstantial evidence that the utterer either forged it or caused its forgery.
– Possession of a falsified instrument by one who benefits from it supports a presumption of guilt.

(Citations: Wharton’s Criminal Law; U.S. v. Britton; Commonwealth v. Talbot; State v. Morgan.)