Goma v. Court of Appeals

Summary

The Supreme Court affirmed the conviction of barangay chairperson Laurinio Goma and secretary Natalio Umale for falsification of public document under Article 171(2) of the Revised Penal Code. Petitioners falsified Barangay Resolution No. T-95 dated September 24, 1995, making it appear that all sanggunian members attended a meeting and unanimously approved PhP18,000 allocation for seminar expenses, when no meeting actually occurred due to lack of quorum. The Court ruled that barangay resolutions are public documents, all elements of falsification were present, and criminal intent is presumed upon execution of the false document. The case establishes that falsification is consummated upon execution of the false document regardless of whether the perpetrators benefited or the public was prejudiced, as what is punished is the undermining of public faith and destruction of truth.