FACTS:

The petitioner, Fernando S. Dizon, was charged with falsification of a private document. It was alleged that he prepared a false certification stating that First United Construction Corporation had undertaken various construction projects for Titan Construction Corporation. During the trial, witnesses testified that the projects mentioned in the certification were never undertaken by First United Construction Corporation and that the signature on the certification was not that of Titan Construction Corporation's former president. The defense presented the petitioner and his father, who testified that the petitioner had no part in preparing the document and did not know who signed the certification. The petitioner's father had issued the certification at the petitioner's request.

Further details reveal that the petitioner, being the Executive Vice President of First United Construction Corporation, requested his father to secure a certification stating that their company had participated in three projects of Titan Construction Corporation. The petitioner's father prepared the certification with the instruction of Jose Caneo, had it signed by Vicente Liwag, and gave it to his son. The petitioner admitted that he had no knowledge of who signed the certification and claimed that he used it on the belief that Titan Construction Corporation had authorized its use.

The trial court found the petitioner guilty of causing the falsification of the certification and using it for a pre-qualification bid. The court also doubted the petitioner's claim of extortion as there was no evidence connecting the alleged extortionists to Titan Construction Corporation.

The petitioner appealed the conviction and argued that the prosecution failed to prove his involvement in the preparation of the falsified certification. He claimed that the sole basis of his conviction was the legal presumption that the possessor of the falsified document is presumed to be the author thereof. He also asserted that the certification may have been furtively issued to assist new construction firms in pre-qualifying for public biddings and that he had no participation in its drafting and issuance.

ISSUES:

1. Whether the prosecution failed to prove that the certification was forged or falsified.

2. Whether petitioner can be convicted of falsification under Article 171, Paragraph 2 of the Revised Penal Code.

3. Whether the signature of Mr. Vicente Liwag was forged.

4. Whether the signature appearing on the certification was forged;

5. Whether the prosecution presented sufficient evidence to prove that the petitioner authored the falsified document.

6. Whether the elements of the crime of falsification under par. 4 of Article 171 are present in the instant case.

7. Whether there is sufficient evidence to prove the guilt of the petitioner beyond reasonable doubt.

8. Whether the evidence presented by the prosecution is sufficient to establish the guilt of the petitioner beyond reasonable doubt

9. Whether the petitioner should be acquitted based on reasonable doubt

RULING:

1. The Court held that the prosecution failed to prove beyond reasonable doubt that the certification was forged or falsified. The testimonies of the prosecution witnesses did not establish with moral certainty that Mr. Liwag did not authorize the issuance of the certification.

2. In order for the petitioner to be convicted of falsification under Article 171, Paragraph 2, it must be proved beyond reasonable doubt that he caused it to appear that Mr. Liwag authorized the issuance of the certification when he did not. Thus, the allegation in the Information must be clearly established.

3. The Court ruled that the signature of Mr. Vicente Liwag was not proven to be forged. The testimonies of the prosecution witnesses did not provide sufficient evidence to establish that Mr. Liwag did not authorize the issuance of the certification.

4. The Court held that the prosecution failed to sufficiently establish that the signature on the certification was forged and that the petitioner authored the falsified document. The testimony of Atty. Linsangan, who stated that he was informed by certain officers of Titan Construction Corporation that the signature appearing on the certification was forged, was hearsay and lacked evidentiary weight. Moreover, the testimony of Jose Caneo, who presumed that it must be the petitioner who delivered the certification based on mere assumptions and speculations, cannot be a basis for conviction. It was also noted that no knowledgeable witness, such as Vicente Liwag, was presented by the prosecution to testify whether the signature on the certification was indeed not by Mr. Liwag. Without clear proof that Vicente Liwag did not sanction the issuance of the certification, the offense of falsification of a private document under Article 172, in relation to par. 2, Article 171, cannot be proven.

5. The Supreme Court held that the elements of the crime of falsification under par. 4 of Article 171 were not present in the case. The Court found that the prosecution failed to prove that the petitioner prepared the document or provided the false information contained in the certification. The Court also noted that there is nothing in the evidence to support the conclusion that the petitioner was in possession of the falsified document. Furthermore, the Court emphasized that the petitioner did not directly benefit from the falsified certificate, as it was the company he worked for that was granted the construction project. Based on the totality of the evidence, the Court found that there is insufficient competent evidence to establish the guilt of the petitioner beyond reasonable doubt. Thus, the petitioner was acquitted.

6. The Supreme Court granted the petition and reversed the decisions of the Court of Appeals and the Regional Trial Court. The petitioner was acquitted of the crime of Falsification of Private Document based on reasonable doubt.

PRINCIPLES:

• In criminal cases, findings of fact by the trial court, as affirmed by the Court of Appeals, are generally given great respect. However, there are exceptions to this rule, such as when the findings are grounded entirely on speculation, surmises, or conjectures, or when the findings are contrary to the evidence on record.

• In order to be convicted of falsification under Article 171, Paragraph 2 of the Revised Penal Code, it must be proved beyond reasonable doubt that the accused caused it to appear in a document that a person or persons participated in an act or proceeding, when they did not actually participate.

• The burden of proof in criminal cases lies with the prosecution, and they must establish the guilt of the accused beyond reasonable doubt. If the prosecution fails to meet this burden, the accused is entitled to an acquittal.

• In criminal cases, the findings of fact and conclusions drawn by the lower courts leading to the accused's conviction must satisfy the standard of proof beyond reasonable doubt.

• Hearsay evidence, or evidence based on what was supposedly told to a witness, does not carry any evidentiary weight.

• Bare assumptions and speculations cannot be the basis for conviction in a criminal offense. A conviction must be based on clear and positive evidence.

• A conviction for falsification of a private document must be based on clear proof that the document was forged or falsified, such as the testimony of knowledgeable witnesses.

• Accusation is not synonymous with guilt.

• In case of doubt, the doubt should be resolved in favor of the accused.

• To secure a conviction, the prosecution must establish the guilt of the accused beyond reasonable doubt.

• Reasonable doubt is that doubt which exists in the mind of a reasonable person after a careful and impartial consideration of all the evidence in the case.

• An acquittal based on reasonable doubt will prevail even if the accused's innocence may be doubted.

• If the facts and circumstances are capable of multiple explanations, one of which is consistent with the innocence of the accused and the other consistent with his guilt, the evidence does not fulfill the test of moral certainty and is not sufficient to support a conviction.