Torres v. People


Torres v. People

G.R. No. 241164

August 14, 2019


                The CA convicted Crizalina B. Torres for the crime of Falsification of Documents under Art. 171 (1,2,4 and 5) of the RPC. The charges involved the petitioner's alleged falsification of the following: ( 1) August 2010 Daily Time Record (DTR); (2) September 2010 DTR; (3) October 2010 DTR; (4) November 2010 DTR; (5) Application for Leave for October 4 to 29, 201 O; (6) and Application for Leave for November 8 to December 10, 2010. She allegedly falsified the respective signatures of officers on her DTRs, making it appear that they verified the same and that she reported for work despite not doing so. Also, she supposedly altered the date of filing of her Applications for Leave, making it appear that they were filed on September 17, 2010 instead of January 18, 2011. The petitioner pleaded not guilty during her arraignment and after the termination of the pretrial conference, trial on the merits ensued.


                Whether or not the CA correctly convicted the accused.


                Yes. First, Jurisprudence is replete with pronouncements that direct evidence is not a condition sine qua non to prove guilt of an accused beyond reasonable doubt. The rationale for this rule is further reiterated in Dungo, et al. v. People of the Philippines, thus direct evidence is not a condition sine qua non to prove the guilt of an accused beyond reasonable doubt. For in the absence of direct evidence, the prosecution may resort to adducing circumstantial evidence to discharge its burden. Crimes arc usually committed in secret and under conditions where concealment is highly probable. If direct evidence is insisted on under all circumstances, the prosecution of vicious felons who commit heinous crimes in secret or secluded places will be hard, if not impossible, to prove. Second, all the elements of the crimes charged were sufficiently established by the prosecution. Petitioner was charged with six (6) counts of falsification of public documents punishable under Article 171 of the RPC, particularly paragraphs 1, 2, 4, and 5.

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