G.R. No. 42557 , December 7, 1935
People of the Philippine Islands vs. Lorenzo Reodica and Sinforoso Cordero

FACTS

Lorenzo Reodica, the municipal treasurer of Bacuit, Palawan, was convicted of falsification of a public document. The information alleged that in July 1931, he falsified a municipal payroll by making it appear that Sinforoso Cordero rendered services as municipal secretary from July 23 to 31, when Cordero was actually absent from the municipality during that period. The evidence showed that the payroll was submitted to Reodica already prepared and signed by the municipal president, who certified that the services were rendered. The payroll included payment for Cordero, who had been granted a leave of absence from July 23 to 31. Reodica paid Cordero’s salary on July 23, although the payroll indicated payment on July 31.

ISSUE

Whether the appellant, Lorenzo Reodica, is guilty of falsification of a public document under the circumstances.

RULING

No. The Supreme Court reversed the conviction and acquitted Reodica. The Court held that Reodica could not be guilty of falsifying the certification that services were rendered, as that certification was made by the municipal president, not by him. Furthermore, the grant of leave to Cordero for the period in question legally amounted to the rendition of service for salary purposes. Any alteration regarding the date of payment (July 23 instead of July 31) did not affect the veracity or legal effects of the document, as the salary was in fact paid. Such alterations do not constitute the crime of falsification.

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