G.R. No. L-91, November 13, 1901
THE UNITED STATES, complainant-appellee, vs. EMILIANO PARAISO, defendant-appellant.

FACTS:
The accused, Emiliano Paraiso, was the agent of the Philippine Commercial Company in Vigan. During May and June 1900, on three occasions, he executed receipts making it appear that one Isabelo Feril had received a total of 485 pesos from the company for the sale of maguey. The accused signed these receipts with the name “Isabelo Feril” and made corresponding entries in the company’s books. At trial, Isabelo Feril testified that the receipts were false. The accused admitted that the signatures were not Feril’s, that he never paid Feril any money, and that he never had a contract with Feril for maguey. A comparison showed the accused made no attempt to imitate Feril’s genuine signature, and there was no similarity between the false and authentic signatures.

ISSUE:
Whether the act of signing a private document in the name of another person without authority, but without any attempt to imitate that person’s signature, constitutes the crime of falsification of a private document under Article 304 of the Penal Code.

RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted the accused. The Court held that to constitute falsification of a private document under Article 304, in relation to Article 300(1) of the Penal Code, it is not enough to merely sign another’s name without authority. The law uses the terms “contrahaciendo o fingiendo” (counterfeiting or feigning), which require an attempt to imitate the handwriting or signature of the person whose name is signed. Since the accused made no attempt to imitate Isabelo Feril’s signature, and the false signatures bore no resemblance to the genuine ones, the essential element of counterfeiting was absent. The Court cited consistent rulings of the Supreme Court of Spain supporting this interpretation. The defendant was acquitted, with costs de oficio.