People vs.

Galano

Facts:

Benjamin Galano used a pre-war one-peso bill of the Treasury of Certificate series for 4 balut eggs. Lilia
Cruz, the balut vendor, said that when she discovered that the bill has the word “Victory” written in ink
at its back, she called Galano but he ran away. He was nabbed and brought to the police for investigation
and wrote a statement that he paid Cruz with a false note.

Galano contended that:

(1) He bought the eggs with a genuine 1 peso bill which was different from the evidence presented to the
police;
(2) He made such statement as the police were shouting at him and was afraid he would be harmed;
(3) His case does not constitute the crime define in Art. 166 (Forging treasury or bank notes)

The State contends that:

(1) Upon examination of the bill, the word Victory was really written in it and when Galano’s run away
after being called by the vendor shows his guilty conscience;
(2) His defense is flimsy since Pat torres, the police, did nothing else to intimidate him except to shout;
(3) The Solicitor General said that, Galano is guilty of Art. 166 in relation to 169.

Held (CA):

Yes, Galano committed forgery under Art. 169 ( par. 1) by giving to a treasury or bank note or any
instrument payable to the bearer or the order mentioned therein, the appearance of a genuine and true
document. The Court believes that this provion contemplates not only the situations where there is a
spurious, false or fake document but also to situations involving originally true and genuine documents
which have been withdrawn or demonetized.

Galano gave it the notion that it’s as if it is a true and genuine legal tender of the Victory series, shows the
intention to deceive and defraud the Government in its avowed duty to protect not only the public but
also the paper bills illegally issued or authorized for circulation.

In this case, Art. 169 paragraph 2, is inapplicable as nothing was erased or altered of figures, letters, etc.
Galano only added the word Victory to make it appear genuine that it used to have before it outlived its
usefulness.