the accused was charged and convicted for Falsification of Public Document

penalized under paragraph 4, Article 171 of the Revised Penal Code (RPC). In this case,

Entienza was, at the time of the commission of the crime, the incumbent Municipal Mayor

of Calauag, Quezon. The charge against him sprung from the complaint of one Adriano

Marana who claimed of having been given of the falsified document – a certification

stating that a certain Annaliza De Torres Prudente is a municipal employee when in fact,

after careful scrutiny of Marana, she is not. Prudente is the former live-in partner of Mayor

Entienza with whom he had two (2) children. The said certification was allegedly signed

and issued by the accused as testified by Marana and by Prudente through a video

recording. The signature was allegedly that of the accused as testified by one Alpuerto

who worked in accused’ office during 2002-2006.

It is noticed in the decision, together with the case’ dissenting opinions, that there

are some points that establishes the presence of reasonable doubt which may warrant

the acquittal of the accused. One major point is the manner of offering the Certificate of

Employment. As pointed by Associate Justice Samuel Martires1, a public document shall

be offered in accordance with the manner provided under Section 24, Rule 132 of the

Rules of Court2. The prosecution fails to show a proof of official record of the said

certification coming from the legal custodian, moreover, the legal custodian said that it

was not issued by the accused. As such, the certification cannot be considered as a public

document and assuming that the signature thereon is that of the accused, the first element

is still not present considering that the document is not a public document or at the very

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2
least, is not intended to serve as such. This already amounts to a reasonable doubt on

the guilt of the accused.