Introduction

In the Philippine legal system, the falsification of documents is a serious criminal offense that undermines the integrity of public and private transactions. This is particularly evident in cases involving the submission of fake receipts, which are often used to support claims for reimbursements, tax deductions, or other financial benefits. The Revised Penal Code (RPC), enacted in 1930 and still the primary source of criminal law in the Philippines, addresses falsification under Articles 171 and 172. These provisions distinguish between falsification by public officers and by private individuals, with the latter being more relevant to scenarios involving fake receipts in everyday business or personal contexts.

This article explores the legal framework surrounding the falsification of documents, with a focus on the liability arising from submitting fake receipts. It delves into the elements of the crime, the penalties imposed, relevant jurisprudence from the Supreme Court of the Philippines, and the potential defense of good faith. Understanding these aspects is crucial for individuals, businesses, and legal practitioners to navigate the complexities of document authenticity in a jurisdiction where trust in written records is foundational to justice and commerce.

Legal Basis: The Revised Penal Code Provisions on Falsification

The RPC provides a comprehensive definition of falsification. Article 171 outlines the acts constituting falsification by public officers, employees, notaries, or ecclesiastical ministers, while Article 172 extends liability to private individuals and the use of falsified documents.

Article 171: Falsification by Public Officers

Under Article 171, a public officer commits falsification if they take advantage of their official position and engage in acts such as:

Counterfeiting or imitating any handwriting, signature, or rubric.
Causing it to appear that persons have participated in any act or proceeding when they did not.
Attributing to persons who have participated in an act or proceeding statements other than those actually made.
Making untruthful statements in a narration of facts.
Altering true dates.
Making any alteration or intercalation in a genuine document which changes its meaning.
Issuing in an authenticated form a document purporting to be a copy of an original when no such original exists, or including statements contrary to or different from the genuine original.
Intercalating any instrument or note relative to the issuance thereof in a protocol, registry, or official book.

This provision is pertinent when fake receipts are issued or altered by government employees, such as in procurement or reimbursement processes within public offices.

Article 172: Falsification by Private Individuals and Use of Falsified Documents

For private individuals, Article 172 penalizes:

Any private individual who commits any of the falsifications enumerated in Article 171 in any public or official document or letter of exchange or any other kind of commercial document.
Any person who, to the damage of a third party or with the intent to cause such damage, makes use of a falsified document.

The second paragraph is especially relevant to submitting fake receipts. It criminalizes the use of falsified documents if it causes damage or is done with intent to cause damage. Receipts, as commercial documents, fall squarely within this scope. For instance, submitting a fabricated receipt to an employer for reimbursement or to the Bureau of Internal Revenue (BIR) for tax purposes could trigger liability under this article.

The RPC defines "documents" broadly to include any writing or paper that evidences a fact or transaction, such as receipts, invoices, or official forms. Fake receipts might involve forging signatures, altering amounts, or creating entirely fictitious documents using software or manual methods.

Elements of the Crime

To establish criminal liability for falsification, the prosecution must prove the following elements beyond a reasonable doubt:

The Document is Falsified: This requires showing that the document was altered, counterfeited, or fabricated in a manner described in the RPC. For receipts, this could include changing the date, amount, or vendor details.
Intent to Falsify or Use: There must be criminal intent (dolo). Mere negligence is insufficient; the act must be willful. In cases of use, the user must know or have reason to know the document is falsified.
Damage or Intent to Cause Damage: For private individuals under Article 172, actual damage to a third party (e.g., financial loss to an employer) or intent to cause such damage is essential. Without this, the act might not constitute a crime, though it could lead to civil liabilities.
Public or Commercial Nature: The document must be public, official, or commercial. Receipts are typically commercial documents, making them subject to these provisions.

In the context of submitting fake receipts, the act of submission itself can constitute "use" if it leads to undue benefit or harm.

Liability for Submitting Fake Receipts

Submitting fake receipts exposes individuals to both criminal and civil consequences. Common scenarios include:

Employment Context: An employee submitting falsified receipts for expense reimbursements commits falsification if the intent is to defraud the employer. This could result in dismissal for cause under the Labor Code, in addition to criminal charges.
Tax Evasion: Using fake receipts to claim deductions or credits with the BIR violates not only the RPC but also the National Internal Revenue Code (NIRC). The BIR may impose penalties, including fines and imprisonment, and refer the case to the Department of Justice for prosecution.
Business Transactions: Vendors or suppliers submitting fake receipts to clients for payment could face charges, especially if it involves government contracts, where it might escalate to estafa (swindling) under Article 315 of the RPC or violations of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019).

Penalties under the RPC vary:

For falsification by public officers (Article 171): Prision mayor (6 years and 1 day to 12 years) and a fine not exceeding P5,000 (adjusted for inflation in practice).
For private individuals (Article 172): Prision correccional in its medium and maximum periods (2 years, 4 months, and 1 day to 6 years) and a fine of not more than P5,000, with higher penalties if damage exceeds certain thresholds.

If the falsified receipt is used in estafa, penalties can compound, leading to longer imprisonment.

The Defense of Good Faith

Good faith serves as a potential defense in falsification cases, rooted in the absence of criminal intent. Under Philippine jurisprudence, good faith negates dolo, which is a requisite for felonies under the RPC (Article 3).

Concept of Good Faith

Good faith implies honesty of intention and freedom from knowledge of circumstances that ought to put one on inquiry. In falsification, a person acting in good faith might believe the document is genuine due to a mistake of fact. For example:

Receiving a receipt from a third party without knowledge of its falsity.
Submitting a receipt altered by someone else, without awareness.

However, good faith must be proven by the accused. It is not presumed; the burden shifts after the prosecution establishes a prima facie case.

Jurisprudential Applications

Supreme Court decisions illustrate the application:

In People v. Sendaydiego (G.R. No. L-33252-54, 1978), the Court held that lack of intent due to reliance on subordinates could mitigate liability, though not fully exonerate if negligence is present.
In Recuerdo v. People (G.R. No. 168217, 2006), the accused was acquitted of falsification for submitting altered documents in good faith, believing them authentic based on representations from others. The Court emphasized that without knowledge of falsity, there is no intent.
Conversely, in People v. Po Giok To (G.R. No. L-12359, 1959), good faith was rejected when the accused should have verified the document's authenticity, indicating recklessness akin to intent.

For fake receipts, good faith might succeed if the submitter was deceived by a vendor or colleague, provided they exercised due diligence. However, willful blindness—ignoring red flags like inconsistencies in the receipt—undermines this defense.

Limitations of the Defense

Good faith does not apply to mala prohibita offenses (strict liability crimes), but falsification is mala in se, requiring intent. Still, in cases involving public documents, courts are stricter, as public trust is at stake.

If good faith fails, mitigating circumstances like voluntary surrender or lack of prior record might reduce penalties under Article 64 of the RPC.

Related Offenses and Civil Remedies

Falsification often intersects with other crimes:

Estafa: If fake receipts are used to deceive and cause pecuniary damage.
Perjury: If submitted in judicial or administrative proceedings under oath.
Violations of Special Laws: Such as the Electronic Commerce Act (Republic Act No. 8792) for digitally falsified documents, or the Cybercrime Prevention Act (Republic Act No. 10175) for online forgery.

Civilly, victims can seek damages under Article 2176 of the Civil Code for quasi-delicts, or file for rescission of contracts tainted by fraud.

Prevention and Best Practices

To avoid liability:

Verify receipt authenticity through cross-checking with vendors or using official BIR-registered formats.
Implement internal controls in businesses, such as dual verification for reimbursements.
Educate on legal consequences to deter intentional acts.

In conclusion, the Philippine legal regime on falsification, particularly for fake receipts, balances punishment with the recognition of good faith defenses, ensuring that only willful acts are penalized while protecting those acting honestly.