G.R. No. 31012 ; September 10, 1932
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. ESTELA ROMUALDEZ and LUIS MABUNAY, defendants-appellants.

FACTS

The accused, Estela Romualdez, was a secretary to Supreme Court Justice Norberto Romualdez and had custody of the 1926 Bar Examination papers. Her co-accused, Luis Mabunay, was a candidate in those examinations. They were charged with falsification of public documents. The prosecution alleged that they conspired to extract Mabunay’s answer sheets from the Supreme Court archives, erase the original failing grades of 58% in Remedial Law and 63% in Civil Law, and alter them to passing grades of 64% and 73%, respectively. These alterations made it appear that Mabunay obtained the required general average, leading to his admission to the practice of law. The original altered documents (Exhibits B-1 and B-2) were presented in evidence.

ISSUE

Whether the accused are guilty beyond reasonable doubt of the crime of falsification of public and official documents.

RULING

Yes. The Supreme Court affirmed the conviction. The Court found that the alterations on the examination papers were undeniable and constituted falsification. The evidence established that Romualdez, who had access to the documents, was responsible for the alterations. As for Mabunay, the Court inferred his guilt from the circumstances, particularly his unexplained withdrawal of a large sum of money around the time of the alterations, which coincided with Romualdez making a substantial bank deposit. His failure to testify or present evidence to explain this suspicious transaction, despite the prosecution’s prima facie case, warranted an adverse inference against him. The Court held that the evidence, though circumstantial, was sufficient to prove conspiracy and guilt beyond reasonable doubt.

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