G.R. No. L-58973-76 July 20, 1982
INOCENTES AMORA, JR., and CLAUDIO MURILLO, petitioners, vs. THE HON. COURT OF APPEALS and THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioners Inocentes Amora, Jr., a municipal employee, and Claudio Murillo, a private contractor, were charged with four counts of Estafa thru Falsification of Public Documents. Murillo was awarded a “pakyaw” contract to supply boulders for a municipal wharf project in Guindulman, Bohol. He utilized workers under a communal “bayanihan” system, paying them a lump sum per truckload. To claim payment from the municipality, however, Murillo prepared and Amora certified daily time books and payrolls listing workers and days of service, which were then approved by the Mayor and Municipal Treasurer. The informations alleged they falsified these payrolls by making it appear certain individuals rendered services when they did not, thereby misappropriating funds.
The Court of First Instance convicted them as charged. On appeal, the Court of Appeals acquitted them of estafa, finding the municipality suffered no loss and even gained from the project. However, it convicted both petitioners of Falsification by Public Officer under Article 171 of the Revised Penal Code. It found Amora, as a public officer, liable for falsification, and Murillo equally liable due to conspiracy. The appellate court also ruled that the four acts constituted a single crime.

ISSUE

The primary legal issue is whether the Court of Appeals erred in convicting the petitioners of falsification by disregarding their defense of good faith and lack of criminal intent.

RULING

The Supreme Court granted the petition and acquitted the petitioners. The legal logic centers on the essential element of criminal intent (mens rea) for the crime of falsification. The Court emphasized the maxim “actus non facit reum, nisi mens sit rea” — an act does not make one guilty unless the mind is criminal. The factual circumstances demonstrated good faith and an absence of malicious intent to cause damage.
The records showed the municipality adopted the “bayanihan” and payroll system for such contracts since 1969. Both Mayor Amora (a lawyer) and the Municipal Treasurer, fully aware of the “pakyaw” nature of the contract, nevertheless approved the payrolls and authorized payments. Crucially, the municipality suffered no actual damage; the project cost was lower than the value of delivered boulders, and the named individuals in the informations suffered no prejudice and were awarded no indemnity. The Court found the petitioners’ resort to the cumbersome payroll system, instead of simple direct billing, was due to ignorance and being ill-advised, not criminal malice. Since the acts were consistent with good faith and no one was prejudiced, the element of malicious perversion of truth was absent. Therefore, no crime of falsification was committed.