G.R. No. L-2752

FACTS:
The defendant, Florentino Sayson, was prosecuted and convicted in the lower court for the crime of falsification of a public document under Articles 300 and 301 of the Penal Code. The falsified documents were certificates of transfer of carabaos. The evidence clearly established that the certificates were false and that the defendant used them, knowing them to be false. The trial court sentenced him to eight years and one day of presidio mayor.

ISSUE:
Whether or not the certificates of transfer of carabaos constitute public documents under Article 300 of the Penal Code, such that their falsification is punishable under Articles 300 and 301.

RULING:
No. The Supreme Court reversed the judgment of the lower court. Following a precedent from the Supreme Court of Spain dated January 15, 1895, which involved practically identical facts from the Province of Pangasinan, the Court ruled that certificates of transfer of carabaos are not public documents within the meaning of Article 300. Instead, they are considered certificates under Article 311 of the Penal Code. Accordingly, the defendant was convicted of a violation of Article 311. He was sentenced to four months of arresto mayor, with the accessories of the law and costs, and with an allowance for one-half of the time of his preventive imprisonment. The case was ordered remanded to the lower court for proper action.