G.R. No. L-2201

FACTS:
The defendant-appellant, Santiago Mateo, admitted to altering a burial permit. He erased the word “Loma,” the name of the cemetery originally designated by the authorities, and inserted the words “Balic-balic,” the name of a different cemetery. He then presented this falsified permit to the authorities of the Balic-balic cemetery, resulting in the burial of the body of Enrique Manalo, whose funeral he had in charge, in that location.

ISSUE:
Whether the burial permit, which was altered by the defendant, constitutes a public document for the purpose of prosecuting the crime of falsification under Article 301 of the Penal Code.

RULING:
Yes. The Supreme Court ruled that the burial permit is a public document, citing Article 1216 of the Civil Code and prior jurisprudence (United States vs. Sarmiento, 1 Phil. Rep., 484; United States vs. Llames, 1 Phil. Rep., 130; United States vs. Barbasa, 1 Phil. Rep., 313). The Court rejected the defendant’s contention that the permit was not a public document and his ancillary argument regarding the description of the Board of Health. Considering the extenuating circumstance under Article 11 of the Penal Code, the Court convicted the defendant of the crime of falsification of a public document. He was sentenced to six years and one day of presidio mayor, a fine of 1,250 pesetas, with the corresponding accessory penalties, and costs.