G.R. No. L-5509
THE UNITED STATES vs. FELIX LOPEZ
March 19, 1910

FACTS: Felix Lopez, postmaster of Indang, was charged with the crime of falsification of a public document. He was accused of certifying official vouchers for the rent of the post office building, making it appear that one Filoteo B. Pepa was the owner of the building and the creditor of the Government for the rent, when Lopez himself was, in truth, the actual owner.

Lopez admitted owning the building. He explained that he had an agreement with Pepa: in exchange for Pepa’s clerk services, Lopez “rented” his house to Pepa, allowing Pepa to then sub-rent it to the government and receive the rent directly. Lopez stated that he believed the term “owner of the building” (as found in a sample voucher prepared by Manila postal authorities, which he followed) was intended to designate the person authorized to contract with the government for rent and receive payments, which Pepa was under their arrangement. He also noted his superficial acquaintance with the English language.

The prosecution admitted that Lopez was duly authorized to disburse the amount paid for monthly rent and that there was no evidence suggesting he received undue profit or that the Government suffered any loss due to the alleged irregularity. It was also noted that no law or regulation prohibited a postmaster from owning the building used as a post office.

ISSUE: Did Felix Lopez, in certifying the vouchers where “owner of the building” appeared after Pepa’s name, knowingly certify a false relation of facts in a public document, thereby committing falsification?

RULING: The Supreme Court REVERSED the conviction and acquitted Felix Lopez.

The Court held that while Lopez was indeed the fee-simple owner of the building, the word “owner” is not uniformly or necessarily limited to that sense. It can be broadly applied to anyone having a defined interest in real estate, including one with an equitable right, a right of possession, or even an occupier in common parlance. Given Lopez’s limited English proficiency and the broad, even “slovenly,” use of “owner” in everyday language, the Court was not convinced beyond a reasonable doubt that he knowingly certified a false statement.

Furthermore, the Court found that Lopez had the right to rent his property to Pepa, allowing Pepa to sub-rent it to the Bureau of Posts. There was no obligation for Lopez to disclose the intricate details of his private agreement with Pepa in the public vouchers. The guide words “owner of the building” in the sample voucher, the Court opined, were likely used in a broader, colloquial signification, to designate any person with lawful authority to make the rental contract. In this broader sense, the contents of the vouchers were “in strict accord with the truth.”

The Court emphasized that no law or regulation prohibited a postmaster from owning the building used as a post office, nor did it appear that the government’s interests were prejudiced. Therefore, Lopez did not commit the crime of falsification.