Scribd
Upload
87 views1 page

Issue: Whether Galano Is Guilty For Violating RPC 169 (1) or RPC 169 (2) - RPC 169 (1) Ruling

Galano was accused of violating RPC 169(1) or 169(2), which involve forgery of government obligations. The court ruled that Galano's escape showed his guilt. His confession to police was invalid because police had no ill motive in arresting him. The court found Galano liable under RPC 169(1) for unauthorizedly adding the word "Victory" to a banknote no longer valid, with intent to deceive the state and public and make the note appear like legal tender. RPC 169(2) did not apply as Galano did not erase or alter existing figures or letters on the note.

Uploaded by

Juan Carlo Castaneda
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
87 views1 page

Issue: Whether Galano Is Guilty For Violating RPC 169 (1) or RPC 169 (2) - RPC 169 (1) Ruling

Galano was accused of violating RPC 169(1) or 169(2), which involve forgery of government obligations. The court ruled that Galano's escape showed his guilt. His confession to police was invalid because police had no ill motive in arresting him. The court found Galano liable under RPC 169(1) for unauthorizedly adding the word "Victory" to a banknote no longer valid, with intent to deceive the state and public and make the note appear like legal tender. RPC 169(2) did not apply as Galano did not erase or alter existing figures or letters on the note.

Uploaded by

Juan Carlo Castaneda
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 1

Issue: Whether Galano is guilty for violating RPC 169 (1) or RPC 169 (2) – RPC 169 (1)

Ruling:
 Galano’s escape was indicative of his guilt. His extrajudicial confession is untenable as the police had no ill-motive to
arrest him and mere shouting does not constitute as intimidation or violence.
 The forgery committed RPC 169 may be done in the following:
o 2. By erasing, substituting, counterfeiting, or altering by any means the figures, letters, or signs contained
therein.
 The SC did not come to a unanimous decision on the matter whether Galano should be punished under RPC 166 or
169. The bill is no longer legal tender. It can be presented to the Central Bank and may only exchange the bill with a
treasury certificates of the Victory series. Unless it is replaced with one of the current Victory notes, even the
Central Bank may not apply a note like that made by Galano in payment of his debts.
 Hence, the unauthorized addition of the word “Victory” was made for the purpose to make it appear that it was true
legal tender of the current Victory series to the end that it may not be refused. The forgery is akin to, or worse than,
affixing the seal to a genuine signature on a document which is invalid w/o a seal.
 Said offense does not constitute estafa as it involves falsification of a gov’t obligation. While the amount is only P1
and can be replaced by money of legal tender, the evil done and its consequences cannot be ignored.
 The alteration/destruction of the billi is harmless except to the holder and would not constitute a crime but for the
utterance of the bill so altered. There was intention to deceive the State in its duty to protect the public and the
paper bills legally issued.
 In this case, RPC 169 (2) is inapplicable as nothing was erased or altered of figures, letters, etc. Galano only added
the word Victory to make it appear genuine that it used to have before it outlived its usefulness. So Galano is liable
for RPC 169 (1)

You might also like