G.R. No. L-2292

FACTS:
The defendant-appellant, Francisco Castro, was charged with the falsification of a private document. The information alleged that on or about February 25, 1903, he signed the name of the deceased Regino Sevilla to a bill of sale for a boat belonging to Sevilla’s estate, with the purpose of defrauding the heirs. The evidence at trial strongly indicated that Castro did sign Sevilla’s name to the document for this fraudulent purpose. However, it was not shown that he attempted to simulate or imitate Sevilla’s genuine signature. Furthermore, evidence indicated that Sevilla himself did not know how to write or sign his name.

ISSUE:
Whether the accused can be convicted of the crime of falsification of a private document under Article 304, in relation to Article 300 of the Penal Code, for signing another person’s name to a document without attempting to simulate that person’s genuine signature.

RULING:
No. The Supreme Court acquitted the accused of the crime of falsification of a private document. Adopting the doctrine established by the Supreme Court of Spain and upheld in prior Philippine jurisprudence, the Court held that a conviction for falsification by attaching another’s signature requires proof that the accused attempted to simulate the genuine signature of that person. Since the evidence failed to establish any such attempt at simulationand, in fact, suggested the deceased could not write his own namethe essential element of the crime was lacking. While the accused’s actions may have constituted another offense such as estafa, they did not meet the legal definition of falsification of a private document as charged. The judgment of conviction was reversed, and the accused was acquitted with costs de oficio.