C/Insp. Ruben Liwanag, Sr. y Salvador vs. People of the Philippines, G.R. No. 202437 (2019)
**Facts:**
– **June 10, 1994:** C/Insp. Ruben Liwanag Sr., a police officer, filled out a Temporary Operator’s Permit (TOP) No. 02774452-A from the LTO, entering the name “Ruben Rubio Liwanag, Jr.” and false information including a falsified birthdate (June 27, 1974) and a misdeclared badge number (from 04580 to 50480). His true birthdate was June 27, 1977.
– **July 3, 1994:** A vehicular accident occurred in Biñan, Laguna involving Ruben Liwanag Jr., who presented the TOP No. 02774452-A instead of a driver’s license to the investigating officer, Conrado Tamayo of PNCC.
– **Investigation:** Certification from the LTO confirmed that Ruben Liwanag Jr. did not have a driver’s license and was thus unauthorized to be issued a TOP.
– **Complaint:** Nelia Enoc and Noel Agcopra, owners of the vehicle involved in the accident, filed a complaint for falsification of a public document against Liwanag Sr. This led to his indictment.
– **RTC Proceedings:** At trial, C/Insp. Antonio Salas testified that the TOP in question was part of his LTO-issued booklet and denied issuing it. During the investigation, it was proven that Liwanag Jr. did not have a driver’s license at the time and obtained one only after the accident.
– **RTC Decision:** The Regional Trial Court (RTC), Branch 6, Manila found C/Insp. Ruben Liwanag Sr. guilty of falsifying the TOP and sentenced him to imprisonment of four (4) years, two (2) months, and one (1) day to six (6) years.
– **Court of Appeals:** On appeal, Liwanag Sr. argued procedural errors, including improper presentation of witnesses and lack of evidence. The Court of Appeals (CA) affirmed the RTC’s decision, noting there was no objection during the trial to the witness testimonies.
– **Supreme Court:** Liwanag Sr. petitioned for review, arguing lack of malicious intent and improper issuance claims.
**Issues:**
1. **Procedural Errors:** Did the trial court err by considering testimony and evidence not formally offered?
2. **Element of Intent:** Is wrongful or malicious intent necessary to convict under Article 171 of the Revised Penal Code for falsification of a public document?
**Court’s Decision:**
1. **Procedural Errors:** The Supreme Court reiterated that the defense waived objections by failing to raise them during trial. Consequently, the evidences and testimonies were legitimately considered. The CA correctly upheld the RTC’s acceptance of the testimonies and documentary evidence.
2. **Element of Intent:** The Court clarified that intent to injure a third party is not an essential element of falsification of a public document. The critical factor is the violation of public trust and destruction of legal truth, not the presence of malicious intent. Thus, the conviction stands on the basis that Liwanag Sr. falsified the public document, irrespective of his personal motives.
**Doctrine:**
– **Falsification by Public Officers:** For falsification of public documents by a public officer under Article 171 of the Revised Penal Code, the principal concern is the integrity of public documents and the violation of public confidence. Malicious intent or gain is immaterial.
– **Procedural Decorum:** Failure to object to the admission of evidence or testimony during trial constitutes a waiver of such objections.
**Class Notes:**
– **Elements of Falsification (Article 171, Revised Penal Code):**
1. **Offender:** Public officer, employee, or notary public.
2. **Advantage of Position:** Offender uses their official position.
3. **Acts of Falsification:** Committing any acts, including making untruthful statements in an official document.
– **Key Statutory Provisions:** Article 171 of the Revised Penal Code, particularly the clause on making untruthful statements in a narration of facts.
– **Interpretation in Context:** The intent to defraud or injure is not necessary; the offense lies in the falsification itself.
**Historical Background:**
This case occurs in a context where integrity in public service is sacrosanct. The 1996 indictment reflects ongoing efforts in the Philippines to hold public officers accountable for abuse of their official position. The doctrine reiterated here emphasizes public faith in official documents, a bedrock principle vital for governance and legal transactions. The case clarifies that integrity and truthfulness in official documents are paramount, regardless of personal motives.
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