G.R. No. 30725 , July 31, 1929
PEOPLE OF THE PHILIPPINE ISLANDS vs. BIENVENIDO MAPA and CECILIO A. TOLEDO

FACTS

An information was filed against Bienvenido Mapa, an employee in the Office of the Clerk of the Supreme Court, and Cecilio A. Toledo, an unsuccessful bar examinee. They were charged with the crime of falsification of an official document. It was alleged that on or about December 17, 1927, they conspired to scratch and erase the name of Vicente A. Rufino from inscription No. 3098 in the Roll of Attorneys (which showed Rufino as a successful bar passer) and insert Toledo’s name in its place. Toledo then signed the falsified entry. Mapa later caused a Certificate of Admission (Exhibit H) to be issued, falsely stating that Toledo’s name appeared on the Roll and that he was authorized to practice law. Both were convicted in the Court of First Instance of Manila. Mapa was sentenced to eight years and one day of prision mayor, a fine, and costs. Toledo was sentenced to four years, nine months, and eleven days of prision correccional, a fine, and costs. Both appealed.

ISSUE

1. Whether the Roll of Attorneys (Exhibit A) is an official document.
2. Whether the evidence, including Exhibit H and the testimony of witness Antonio Hipolito, sufficiently proves the guilt of both accused and the existence of a conspiracy between them.

RULING

1. Yes, the Roll of Attorneys is an official document. The Supreme Court held that the Roll (Exhibit A) is an official book of the court. It is kept in the Clerk’s office among other court records, contains entries signed by the attorneys admitted and attested by the Clerk or Deputy Clerk, and is open to public inspection. Entries made therein are therefore official documents.
2. Yes, the guilt of both accused and the conspiracy between them were proven beyond reasonable doubt.
For Bienvenido Mapa: The evidence showed he was a trusted employee in charge of the records. He knew Toledo had not passed the bar. He procured the falsification of the Roll entry and personally delivered the blank Certificate of Admission (Exhibit H) to Antonio Hipolito with instructions to insert Toledo’s name, knowing it was based on a falsified record. His actions constituted direct participation in the crime.
For Cecilio A. Toledo: The evidence showed he knew he had failed the bar examination (receiving only 57%). Despite this, he signed the falsified Roll entry (No. 3098), which was originally issued to Vicente Rufino, and later accepted the Certificate of Admission (Exhibit H) knowing it was fraudulently obtained through the falsified record.
The coordinated actions of Mapa and Toledo in altering the official record and generating a false certificate based on that alteration established their conspiracy.

The Supreme Court AFFIRMED the conviction of both appellants. However, the Court MODIFIED the sentence of Bienvenido Mapa by revoking the portion imposing subsidiary imprisonment for non-payment of the fine, in view of his principal penalty of eight years and one day of imprisonment. The judgment against Cecilio A. Toledo was affirmed in its entirety.