GR L 6222; (December, 1910) (Digest)
G.R. No. L-6222
THE UNITED STATES, plaintiff-appellee, vs. CRISTOBAL GROSPE (alias CAYETANO ASUNCION ), defendant-appellant.
December 10, 1910
FACTS:
Cristobal Grospe (alias Cayetano Asuncion) was employed as a capataz by the Tarlac Railway Company. His duty included submitting daily time reports listing the laborers under his charge. On April 20, 1909, Grospe submitted a time report (Exhibit A) indicating that eleven laborers had worked that day. Based on this report, the company paid all eleven men. However, it was later discovered that only five of the eleven men had actually worked for the company on that date. Consequently, the company paid six men for services they never rendered, resulting in actual prejudice and damage to the company. Grospe initially claimed he was induced to falsify the report but later insisted all eleven men had worked. He had a prior dismissal for theft from the same company and used an alias. Grospe was charged with falsification of a private document, found guilty by the Court of First Instance, and sentenced to presidio correccional, a fine, and subsidiary imprisonment. He appealed this judgment.
ISSUE:
Did the appellant’s act of submitting a false daily time report, which is a private document, by including individuals who did not work, to the prejudice of the company, constitute the crime of falsification under the Penal Code?
RULING:
Yes. The Supreme Court AFFIRMED the judgment of the lower court. The Court ruled that Cristobal Grospe was guilty of falsification of a private document. His act of including the names of six non-working men in the daily time report fell under the acts of falsification specified in Article 300 of the Penal Code, specifically “including in any act the participation of persons who had no such participation” and “perverting the truth in the narration of facts.” As these acts were committed in a private document (the time report) to the prejudice of a third person (the Tarlac Railway Company), and with clear intent to cause damage, they constitute the crime of falsification under Article 304 of the Penal Code. The company suffered actual damage by paying for services that were not performed due to the appellant’s false report.