PREFATORY STATEMENT

It is an established rule that when a person has in his

possession a falsified document and makes use of the
same, the presumption or inference is justified that
such person is the forger.1

The Court laid down the rule that the utterance or use
of a forged instrument, when unexplained, is strong
evidence tending to establish that the user himself (or
herself) either forged the instrument or caused it to be
forged.2

The submission of the previously inexistent document

with the government subjects the accused-petitioner to
the inference that he used it as part of the registration
papers. In the absence of a credible and satisfactory
explanation of how the document came into being and
then filed with the government agency, the accused is
presumed to be the forger. Having been the one
responsible for the filing of the registration papers,
including the means he felt necessary to accomplish
the registration, the accused must likewise be
accountable therefor. As the authorized representative,
he is deemed to have been the one in custody or
possession, or at least the one who has gotten hold
even for a short while, of the papers which included
the [falsified document]. That he knew of the
execution of the statement is a possibility not too
difficult to imagine under the circumstances.3 (italics
supplied)

1 U.S. vs. Viloria, 1 Phil. 682

2 U.S. v. Castillo

3 Caubang v. People