FACTS:
On August 9, 1906, Marcelo F. Concepcion, then the treasurer of Guindulman, Bohol, prepared the payroll for municipal officers and employees. He submitted this payroll to the district auditor as a voucher for his accounts, certifying under oath that the amounts listed therein had been duly paid as salaries. However, this was false, as several employees had not received the sums stated as having been paid. This act constituted the crime of falsification of a public document by perverting the truth in the statement of facts, as defined in No. 4 of Article 300 of the Penal Code. The lower court found Concepcion guilty, imposing a penalty of fourteen years eight months and one day of cadena temporal and a fine of 1,250 pesetas. The lower court also ordered him to indemnify the employees for the unpaid sums. The total deficit in the municipal treasury resulting from the falsification amounted to P275.74.

ISSUE:
1. Whether Marcelo F. Concepcion was guilty of falsification of a public document.
2. Who was the proper party to receive the indemnity for the falsified payments.

RULING:
The Supreme Court, in G.R. No. 4032 , on August 15, 1908, affirmed the conviction of Marcelo F. Concepcion for the crime of falsification of a public document and upheld the imposed penalty.

However, the Court modified the judgment concerning the indemnity. It held that the employees were not the injured parties because they retained their right to recover their full salaries from the municipality. The falsification, which involved the municipal funds under the pretext of making payments, solely affected the municipality, which owned those funds. Therefore, the municipality of Guindulman was the only aggrieved party and was entitled to the indemnity. The Court ordered that the payment of the indemnity, amounting to P275.74, be made in favor of the municipality of Guindulman.