26. THE PEOPLE OF THE PHILIPPINE ISLANDS vs.
ESTELA ROMUALDEZ and LUIS
MABUNAY
G.R. No. 31012 September 10, 1932
ARTICLE 171 FALSIFICATION OF PUBLIC DOCUMENTS
MAINPOINT:
Esteka Romualdez, appointed as secretary of Honorable Norberto Romualdez ,
taking advantage of her position, who alters the grades of the bar examinee Luis
Mabuhay by erasing and indicating a grade making it appear that Luis Mabuhay obtained
the general average required by the Suppreme Court, with her admission, should be held
guilty of Falsification of Public Documents under Article 171 of the Revised Penal Code.
FACTS:
On February 1927, the accused Estela Romuladez who by appointment of the Supreme
Court, was them taking part in the discharge of public functions as secretary top the Honorable
Norberto Romualdez, extracted from the said archives of the Supreme Court certain public and
official documents to wit: the composition, which were written, prepared and submitted by the
accused, Luis Mabunay, in that examination, the said accused, Estela Romualdez and Luis
Mabunay, conspiring together and acting in common accord, erased the grades given by the
correctors on subjects Remedial Law, Civil Law and by means of these alterations the accused
Romualdez and Mabunay thus succeeded by means of the falsifications made by them in the
aforesaid public and official documents in making it appear that Luis Mabunay obtained the
general average required by the rules of the Supreme Court, and in securing the latter’s
admission to the practice of law, as in fact he was admitted, to the great prejudice of the public.
ISSUE:
Whether or not Estela Romualdez is guilty of falsification of public documents.
RULING:
Yes. Justice Romualdez was designated by the Chief Justice to conduct the examination
in accordance with the law and the Rules of Court. He himself had no such authority as he is
alleged to have given his secretary. The accused made the alterations in a way as to make it
appear that the correctors had participated therein, because she blotted out the grades of the
correctors and wrote the new grades opposite their initials.
One of the punishable acts under Article 171 of the Revised Penal Code , Falsification
by public officer, employee or notary or ecclesiastical minister is Falsifying Public Document
Causing it to appear that persons have participated in any act or proceeding when they
did not in fact so participate.
