G.R. No. L-5801, January 13, 1911, THE UNITED STATES vs. ISAAC WILLIAMS

FACTS:
Isaac Williams, a road and bridge foreman (capataz encargado) in Lucena, Tayabas, was charged with falsification of an official document. The information alleged that in July 1909, Williams certified a pay roll (Exhibit B) as correct, stating that laborer Emetrio Macatangay worked 11 days for the provincial government, when in truth Macatangay worked only 3 days for the government and 8 days for Williams. The prosecution’s theory was that Macatangay was actually driving a cart and carabao belonging to Williams during those 8 days, and by having Macatangay listed as a day laborer, Williams caused the government to pay wages that should have been his own responsibility. The trial court convicted Williams and sentenced him to cadena temporal.

ISSUE

Whether the evidence presented by the prosecution sufficiently proves beyond reasonable doubt that Isaac Williams is guilty of falsifying an official document.

RULING

No. The Supreme Court acquitted Isaac Williams. The evidence failed to establish his guilt. Key points from the Court’s analysis:
1. The pay roll (Exhibit B) was prepared by clerks using time books kept by subordinate capataces (like Canuto Manalo), not by Williams. Williams only certified it after it was made.
2. The prosecution’s claim that Macatangay drove Williams’ cart and carabao for 8 days is unsupported. Testimony from Capataz Manalo was inconsistent and did not definitively state that Williams owned the cart or paid Macatangay. Macatangay himself denied working for Williams and claimed he was sick during the first two weeks of July.
3. Evidence showed Williams did not own a carabao and cart until July 11, making it impossible for Macatangay to have driven for him on July 1-3 as alleged.
4. The separate voucher for cart drivers (Exhibit C) was unimpeached. If Macatangay was driving for Williams, Williams’ namenot Macatangay’sshould have appeared on that voucher as the party to be paid by the government.
The Court found the evidence insufficient to prove falsification. The judgment of conviction was reversed, Williams was acquitted and ordered immediately released, with costs de oficio.