G.R. No. L-5307
THE UNITED STATES, plaintiff-appellee, vs. JOSE GONZAGA CHANGCO, defendant-appellant.
December 3, 1909

FACTS:
Jose Gonzaga Changco, the municipal treasurer of Bacolod, along with municipal president Mariano Ramos and clerk Fernando Jarabas, were charged with falsification of public documents under Article 300 of the Penal Code. The charge stemmed from a scheme where Ramos simulated a contract between the municipality and one Enabe for supplying rations to quarantined persons. Jarabas presented accounts with forged Enabe signatures to Ramos, who approved them. Jarabas then presented these vouchers, with forged Enabe receipts, to Gonzaga for payment. Gonzaga paid the amounts to Jarabas (instead of Enabe) and subsequently included these payments in his accounts-current with the Government as having been made to Enabe. In reality, Enabe never had such a contract, never signed any documents, and never received any money. Jarabas was convicted in a separate trial, while Ramos was acquitted. The trial court found Gonzaga guilty of falsification of public documents, concluding he must have known of the falsity and intended to defraud the government.

ISSUE:
Was Jose Gonzaga Changco guilty of the crime of falsification of public documents, given the absence of direct proof of his knowledge of the falsity of the documents or his intent to defraud the government?

RULING:
No. The Supreme Court reversed the trial court’s decision and acquitted Gonzaga. The Court held that knowledge of the falsity of the documents was essential for criminality on the part of Gonzaga, and the prosecution failed to establish this knowledge. The burden was on the Government to prove that Gonzaga was a party to the scheme by which the municipality was defrauded, or that he used the false documents with knowledge of their falsity for purposes of gain to himself. There was no evidence connecting Gonzaga with the preparation of the documents. While the transaction was irregular and Jarabas presented false documents, the accounts and vouchers appeared regular in form. Furthermore, rice was indeed being furnished to quarantined persons, and Jarabas was involved in its distribution, which could have led Gonzaga to believe the documents were legitimate. The Court found no evidence to sustain the trial court’s conclusion that Gonzaga knew Enabe had no contract or that he aided in preparing/using the false documents with intent to defraud. The failure to strictly follow a perceived duty (e.g., paying only to the named person and witnessing a signature), which was not shown to be mandated by law, did not equate to the crime of falsification in the absence of criminal intent and knowledge.