G.R. No. L-2284

FACTS:
The defendant-appellant, Jose Paraiso, was the municipal treasurer and acting deputy provincial treasurer of Lumbang. He was charged with the crime of falsification of a public document under Article 300 of the Penal Code. The prosecution proved that Paraiso collected poll taxes from residents in amounts exceeding the lawful rate. He then entered smaller amounts on the corresponding certificate stubs and, based on these falsified stubs, prepared and certified official abstracts of collections which he presented to the provincial treasurer. By this means, he retained the difference for his personal use. During trial, witnesses, including the provincial treasurer, testified to the discrepancies between the amounts on the issued certificates and the stubs, and Paraiso’s own admission was presented.

ISSUE:
Whether the defendant-appellant is guilty of the crime of falsification of a public document as charged.

RULING:
Yes, the defendant-appellant is guilty. The Supreme Court affirmed the judgment of the trial court. The act of preparing and presenting an official abstract of collections based on falsified stubs constitutes falsification of a public document under Article 300 of the Penal Code. The abstract, being a certified official document submitted to a superior, contained false entries regarding the amounts collected, made with intent to gain. The Court rejected the defense’s arguments, including the claim of multiplicity of crimes, holding that the complaint properly charged only one complex crime of falsification through a series of acts, to which no demurrer was interposed. No aggravating or mitigating circumstances being present, the penalty imposed by the lower court was sustained.