G.R. No. 31049 , November 29, 1929
PEOPLE OF THE PHILIPPINE ISLANDS vs. JUSTO A. PONFERRADA, ET AL. (Virgilio Naval, Appellant)

FACTS

Justo A. Ponferrada, a law graduate, failed the bar examinations four times, the last in 1927 with a grade of 61%, far below the passing mark of 75%. After this final failure, he contacted Virgilio Naval, then a private secretary to a Supreme Court Justice. Naval agreed to help “fix” Ponferrada’s grades for a fee of P900, which Ponferrada paid. Subsequently, Naval, with the assistance of Albino Candelaria (a clerk of court employee), delivered to Ponferrada a falsified copy of a Supreme Court resolution admitting him to the bar and later a fake diploma. To complete the fraudulent admission, Naval and Candelaria, with the help of a janitor, took the official Roll of Attorneys (a register kept by the Supreme Court) from the clerk’s office. They then drove Ponferrada and two other failed candidates to San Juan Heights, where, using a car’s tail-light for illumination, the candidates signed their names in the Roll over erasures of legitimately admitted lawyers’ names. Naval was charged with falsification of a public document. He was convicted by the Court of First Instance of Manila, prompting this appeal.

ISSUE

1. Whether the evidence, primarily based on the uncorroborated testimony of co-accused Ponferrada, is sufficient to convict Naval.
2. Whether the Roll of Attorneys is a public or official document, the falsification of which is punishable under Article 301 of the Penal Code.
3. Whether the Court of First Instance of Manila had territorial jurisdiction over the offense, which was physically committed in San Juan Heights.

RULING

The Supreme Court AFFIRMED the conviction.

1. On the sufficiency of evidence: The testimony of an accomplice (Ponferrada) is admissible and can be the basis for conviction if found credible. The Court found Ponferrada’s testimony not only credible but also corroborated by the undeniable fact of the falsification itself and the circumstances surrounding it.

2. On the nature of the document: The Roll (Register) of Attorneys is a public and official document. It is a final repository of the Supreme Court’s resolutions on bar admissions and is required to be kept by the Clerk of Court under the Code of Civil Procedure. The entries therein are not mere certificates but official records showing that the named individuals have taken the required oath and been admitted to practice.

3. On territorial jurisdiction: The Court of First Instance of Manila has concurrent jurisdiction over crimes committed within a zone extending 2.5 miles from the city limits. The trial court could take judicial notice that San Juan Heights, where the falsification was committed, is within this jurisdictional zone.

The offense is penalized under Article 301 of the Penal Code. The Court upheld the imposition of the penalty in its maximum degree due to the aggravating circumstance that Naval availed himself of his official position as a Supreme Court employee in committing the crime.