G.R. No. L-23625, L-23626, L-23627. November 25, 1983.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. MARIANO TERRADO, et al., defendants-appellees.

FACTS

The cases involve three consolidated criminal cases for falsification of public documents under Article 171 of the Revised Penal Code. The accused, including applicants for free patents (Gertrudes Obo, Remedios Gundran, Mariano Terrado) and public officers (Pedro Terrado, Casimiro Flores, Bruno Gundran), were charged for conspiring to prepare and submit falsified documents—such as applications, notices, and inspection reports—to secure free patents for parcels of land in Camarines Sur from 1951 to 1953. The informations alleged they made false representations regarding the applicants’ qualifications and the land’s disposable character, knowing these to be fraudulent.
Before arraignment, the accused filed motions to quash, arguing the acts constituted not falsification but other offenses like perjury under Commonwealth Act No. 141 or violations of the Revised Administrative Code, and that the crimes had prescribed. The trial court dismissed all three cases on April 15, 1963, agreeing that the crimes had prescribed. The People appealed, contending the informations properly alleged falsification of public documents and that the prescriptive period had not lapsed.

ISSUE

Did the trial court err in dismissing the criminal cases on the ground of prescription?

RULING

No, the trial court correctly dismissed the cases. The Supreme Court affirmed the dismissal, ruling that the offenses had prescribed. While the informations sufficiently alleged the crime of falsification of public documents under Article 171 of the Revised Penal Code, the acts described also constitute perjury under Section 129 of Commonwealth Act No. 141, which specifically penalizes the presentation of false evidence or affidavits concerning public lands. Applying the rule that penal laws must be construed strictly against the government and liberally in favor of the accused, the Court held that the more favorable prescriptive period should govern.
Falsification under Article 171 carries prision mayor, an afflictive penalty prescribing in 15 years under Article 90 of the Revised Penal Code. Perjury under Article 183 of the Revised Penal Code is a correctional penalty prescribing in 10 years. However, perjury under the special law (Commonwealth Act No. 141) is subject to Act No. 3326, as amended, which sets an eight-year prescriptive period for offenses punishable by imprisonment of two years or more but less than six years. Since the perjury penalty falls within this range, the eight-year period applies. The offenses were committed between 1951 and 1953, but the informations were filed only on March 13, 1962, clearly beyond eight years. Thus, the crimes had prescribed, warranting dismissal. The Court emphasized this application as more favorable to the accused, aligning with fundamental principles of criminal law.