The United States v. Santiago Mateo

Summary

Santiago Mateo was prosecuted for falsifying a burial permit by erasing 'Loma' cemetery and inserting 'Balic-balic' cemetery, then using the altered document to bury Enrique Manalo. The Supreme Court rejected his defenses that the burial permit was not a public document and convicted him under Article 301 of the Penal Code. The Court applied extenuating circumstances under Article 11 but still imposed the penalty of six years and one day imprisonment plus a fine of 1,250 pesetas. This early 1905 case established precedent regarding the public document nature of burial permits and the criminal liability for their falsification during the American colonial period in the Philippines.