G.R. No. L-49483 March 30, 1981
SALUD P. BERADIO, petitioner, vs. THE COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Salud P. Beradio, an election registrar of the COMELEC in Rosales, Pangasinan, was convicted on four counts of falsification of public documents under Article 171, paragraph 4 of the Revised Penal Code. The charges stemmed from her making false entries in her Daily Time Records (DTRs) for specific dates in 1973, wherein she indicated she was present and working in her office. The prosecution established that on those very dates, Beradio was actually appearing as counsel in various court proceedings before different branches of the Court of First Instance and the Court of Agrarian Relations in Pangasinan. The trial court acquitted her on three charges but convicted her on four counts, a decision affirmed in toto by the Court of Appeals.
Beradio filed a petition for review, arguing that her guilt was not proven beyond reasonable doubt. She contended that her court appearances were in the capacity of a counsel de oficio or under legal assistance programs, constituting a valid performance of her official duties, and thus her entries in the DTRs, while technically inaccurate as to her physical location, did not constitute criminal falsification as they lacked deliberate intent to falsify.

ISSUE

Whether the petitioner’s act of indicating in her Daily Time Records that she was in her office, when she was in fact attending court hearings as counsel, constitutes the crime of falsification of public document under Article 171 of the Revised Penal Code.

RULING

The Supreme Court reversed the conviction and acquitted Salud P. Beradio. The Court held that the element of deliberate intent to falsify (animus falsandi) was not established beyond reasonable doubt. For falsification under Article 171 to be consummated, the act must be done with malicious intent to cause damage or with the intent to commit fraud. The Court found that Beradio’s court appearances were made in an official capacity, pursuant to her duties as a lawyer and under existing legal assistance programs like the Citizen’s Counselor Act. These appearances were matters of public record and were not concealed. Her act of reporting for work in her DTR, while she was performing a different but still official function, lacked the perverse criminal intent required for the crime. The inaccuracy in her DTR, under these specific circumstances, was a mere irregularity without criminal malice. Consequently, her guilt was not proven to the required moral certainty.