Reodica v Court of Appeals, G.R. No.

L-42557, December 7, 1935

Doctrine: In a case of falsification of a public document, the person who certifies the services mentioned
in the document is responsible for its veracity, not the person who merely receives and approves the
document for payment. Alterations in the document that do not affect its veracity or its effects do not
constitute the crime of falsification.
Section Four. - Falsification of legislative, public, commercial, and private documents, and wireless,
telegraph, and telephone message. Five Classes of Falsification

1. Falsification of legislative documents (Art 170)

2. Falsification of a document by a public officer, employee or notary public (Art. 171)

3. Falsification of a public or official, or commercial document by a private individual (Art. 172, par 1)

4. Falsification of a private document by any person (Art. 172, par 2)

5. Falsification of wireless, telegraph and telephone messages (Art. 173)

Facts: Lorenzo Reodica, the appellant, was the municipal treasurer of Bacuit, Province of Palawan, around
July 1931. He was charged with falsifying a municipal payroll for that month, specifically by indicating
that Sinforoso Cordero, a municipal secretary, had rendered services from July 23 to July 31, even though
Cordero had been absent from Bacuit during that period.

The evidence presented during the trial showed that the municipal payroll had been prepared and signed by
the municipal president, who also authorized the payment of Cordero's salary for that period. When Reodica
received the payroll on July 23, it was already signed, approved by the president, and certified to reflect the
services rendered.

Ruling: The Supreme Court held that Reodica was not guilty of falsifying the payroll because the
responsibility for certifying the services mentioned in the document rested with the municipal president,
not Reodica. While the information alleged that Reodica certified the payment of Cordero's salary on July
31, it did not assert that this was untrue. Moreover, the fact that the payment was made on July 23 instead
of July 31 was immaterial because Cordero had indeed rendered services during that period due to the leave
granted to him.

The Court also emphasized that alterations in the document that do not affect its veracity or its effects do
not constitute the crime of falsification. As a result, the judgment against Reodica was reversed, and he was
acquitted. Costs were also waived.