G.R. No. L-7236; April 30, 1955
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. PO GIOK TO, defendant-appellee.

FACTS

The defendant, Po Giok To, was charged in the Court of First Instance of Cebu with the crime of falsification of a public document. The information alleged that on or about January 7, 1952, in Cebu City, the accused, with intent to falsify, willfully falsified Residence Certificate No. A-1618529 by misrepresenting to the City Treasurer’s representative that his name was Antonio Perez, his place of birth was Jaro, Leyte, and his citizenship was Filipino. Based on these misrepresentations, the representative issued the certificate with those false entries, when in truth the accused’s name was Po Giok To, his place of birth was Amoy, China, and his citizenship was Chinese. The accused filed a motion to quash the information, arguing it failed to allege that he had an obligation to disclose the truth and that he had a wrongful intent to injure a third person. The lower court granted the motion and ordered amendment. Upon the City Fiscal’s insistence that the information was sufficient and that he lacked evidence of the accused’s use of the falsified certificate, the court dismissed the case without prejudice. The Government appealed.

ISSUE

Whether the information alleges sufficient facts to constitute the crime of falsification of a public document.

RULING

Yes. The Supreme Court reversed the trial court’s order of dismissal and remanded the case for further proceedings. The Court held that the information was sufficient. First, the obligation of the accused to disclose the truth regarding the facts required in a residence certificate (name, place of birth, citizenship, etc.) is inherent under Section 3 of Commonwealth Act No. 465 (Residence Tax Act), which mandates these details to establish the holder’s correct identity. Therefore, there was no need to expressly allege this duty in the information. Second, wrongful intent to injure a third person is not an essential element of the crime of falsification of a public document by a private individual under Article 172(1) in relation to Article 171(4) of the Revised Penal Code. Such intent is required only for falsification of private documents under Article 172(2). The principal evil punished in falsifying public documents is the violation of public faith and the destruction of truth in official records. The accused’s acts, if proven, would cause prejudice to the Government by creating confusion in its records. Furthermore, the accused, as a private individual, could be held liable as a principal by inducement for causing the public employee to innocently write the false entries. Finally, the existence of a special law ( Commonwealth Act No. 465 ) punishing certain falsifications of residence certificates does not preclude application of the general falsification provisions in the Revised Penal Code, as the latter applies supplementally under Article 10. Whether the crime falls under the Revised Penal Code or Section 12 of Commonwealth Act No. 465 is a matter for determination on the merits, but the information was sufficient to charge an offense.