The United States v. Frank de L. Carrington

Summary

Major Frank de L. Carrington was prosecuted for falsifying a public voucher while serving as disbursing officer for Philippine Scout funds. He certified purchasing lumber for P770 that was never actually bought. The Supreme Court rejected his claims to jury trial rights and upheld his conviction for falsification under Article 300 of the Penal Code. The Court established that his appointment as disbursing officer made him a public official, the voucher was a public document, and his certification of a non-existent purchase constituted criminal falsification. The case demonstrates early application of Spanish Penal Code provisions during the American colonial period and clarifies that U.S. military personnel in the Philippines were subject to local court procedures rather than constitutional jury trial rights.