Manuel L.

Siquian
Vs.
The People of the Philippines
G.R. No. 82197

FACTS: Complainant Jesusa Carreon went to the accused Manuel L. Siquian,the

Municipal Mayor of Angandanan, Isabela to apply for the employment in the
Office of the Mayor. The mayor agreed to employ her. The accused told her
to report for work the following day and that she should be included in the
budget. One week after, the accused told her to go back to the Municipal
Secretary to work for her appointment. She was appointed clerk to the
Municipal Secretary in the Office of the Municipal Secretary on July 1,
1975. Accompanying her appointment is the certification of the availability
of funds issued by the accused.

Complainant took her oath of office and rendered services for the
months of July, August, September, October, November and December 1975 with
a salary of 120.00 however she was not paid. It turned out that no such
found available and the position of Clerk to the Municipal Secretary does
not exist. Because of this, complainant did not receive any salary. It also
appears from the evidence that the municipal council of Angandanan, Isabela
failed to enact the annual budget for the Fiscal Year 1975-1976. Pursuant
to PD No. 477, the annual budget for previous Fiscal Year 1974-1975 was
deemed re-enacted. Thus the Municipal Plantilla of Personel is the same
Plantilla of Officer of the previous Fiscal Year and no supplemental budget
was enacted by the municipal council of Angandnan. Complainant instituted a
complaint for falsification.

RTC found the accused guilty of the crime of falsification of

documents under Art. 171 of the RPC. Court of Appeals affirmed the trials
court decision.

On appeal, the accused contends that there was an absence of criminal

intent on his part to injure any person. That there was no evidence that
the accused took advantage of his position when he made the allegedly
falsified certification. Furthermore, he contends that the statement he
made in the certification is conclusions of law and not narration of facts.
Thus, he cannot be held criminally liable.

ISSUE: WON the accused committed falsification?

HELD: Yes. The offense of falsification of offense under Article 171 of the
RPC is committed by any public officer, employee or notary who, taking
advantage of his official position shall falsify a document by committing
the following acts: 4. Making untruthful statements in a narration of
facts; It is settled that in this fourth kind of falsification, the
following requisites must concur: (a) That the offender makes in document
untruthful statements in a narration of facts; (b) That he has a legal
obligation to disclose the truth of facts narrated by him; and (c) That the
facts narrated by the offender is absolutely false.

In the case at bar, all the requisites for falsification had been
fully met. Accused, a public officer, being then the mayor made an
untruthful statement in the narration of facts contained in the
certification which he issued in connection with the appointment of
complainant. The certification, having been issued by a public official in
the exercise of the function of his office is a public document. Since the
certification was prepared by the accused in accordance with the standard
forms prescribed by the government pursuant to law, the certification was
invested with the character of a public document.

Contrary to the petitioners claim the existence of wrongful intent to

injure a third person is not necessary when the falsified document is a
public document. Wrongful intent on the part of accused is not an essential
element of the crime of falsification of public document.

Supreme Court affirmed the decision of the Court of Appeals.