G.R. No. L-2054

FACTS:
Matias Bunagan, the duly appointed municipal treasurer of Enrile, Cagayan, was charged with falsification of public documents. The information alleged that in November 1903, in abuse of his office, he made false entries in the municipal account books and in a specific voucher. These entries purported to show salary payments to eleven members of the municipal police force for the months of September, October, and November, when in fact no such payments had been made.

ISSUE:
Whether the trial court erred in convicting the accused and whether the penalty imposed was correct in light of the applicable provisions of the Penal Code.

RULING:
The Supreme Court affirmed the conviction, finding no prejudicial error in the proceedings and that the evidence fully sustained the trial court’s findings. However, the Court modified the penalty. The trial court had sentenced Bunagan to twelve years and one day of cadena temporal but failed to impose the mandatory fine and the accessory penalties required by law for the crime of falsification of public documents under Article 300 of the Penal Code. Accordingly, the Supreme Court modified the sentence by adding a fine of 2,000 pesetas and imposing the accessory penalties prescribed in Article 56 of the Penal Code. The judgment was affirmed as modified, with costs against the appellant.