G.R. No. L-2607

FACTS:
Fernando Nieto, the municipal president of Meycauayan, purchased a typewriter for the municipality for $90 (gold). He obtained a receipt and reimbursement voucher from the vendors for that amount. Nieto later altered both documents to state the purchase price as $95 (gold). Using these falsified documents, he obtained reimbursement from the municipal treasurer for 190 pesos (Philippine currency), thereby receiving an excess equivalent to $5 (gold). At trial, he was convicted of falsification of a private document. Nieto appealed, claiming his alterations caused no actual damage (perjuicio) to the municipality, as he allegedly spent an extra $5 for typewriter suppliesan essential element for the crime under the Penal Code.

ISSUE:
Whether the accused is guilty of the crime of falsification of a private document, considering his claim that the alteration caused no actual damage to the municipality.

RULING:
Yes, the accused is guilty. The Supreme Court affirmed the trial court’s judgment. The documents (receipt and voucher) were private in character at the time of falsification, as they merely evidenced a private transaction between Nieto and the vendors and had not yet become part of any official public record. The Court found Nieto’s justificationthat the alteration was to recover a separate $5 spent on suppliesto be untrue. The evidence established that the supplies were included in the original $90 purchase price, and thus the alteration did cause actual pecuniary damage to the municipality. Since the essential element of damage was present, his conviction for falsification of a private document stands.