Penalty for Falsification of Bank Receipts in the Philippines (Updated to June 16 2025)
1. What counts as a “bank receipt”?
For criminal-law purposes, the term embraces any written or electronic acknowledgment issued by a bank—e.g., deposit slips, withdrawal slips, official receipts for fees, manager’s-cheque stubs, debit or credit memos, printed or e-receipts for online and mobile-banking transactions. Because a bank is engaged in commerce, these instruments are ordinarily treated as commercial documents under Article 522 (now Art. 172 par. 2) of the Revised Penal Code (RPC). Exception: if the bank is government-owned (e.g., Land Bank, DBP), a receipt issued by its teller can be deemed a public document, invoking Art. 171 when the falsifier is a public officer.
2. Core offense and its elements
| Provision | Offender | Document class | Elements (simplified) |
|---|---|---|---|
| Art. 171 RPC | Public officer or employee | Public document | (a) Takes advantage of official position; (b) commits any of the eight acts of falsification (counterfeiting signatures, making untruthful statements, altering true dates, etc.); (c) intent to gain or prejudice not required. |
| Art. 172 ¶2 RPC | Private individual | Commercial document (incl. bank receipts) | (a) Knows the document to be false; (b) performs any act of falsification under Art. 171; (c) document is issued for trade or commerce. |
| Art. 172 ¶3 RPC | Any person | Private document | Same acts; requires intent to cause damage or at least that damage could result. |
Using a falsified receipt to defraud the bank or a third person produces the complex crime of estafa through falsification (Art. 48 RPC): a single penalty, applied as that for the more serious offense, in its maximum period.
3. Statutory penalties (as amended by R.A. 10951, 2017)
| Scenario | Imprisonment | Fine |
|---|---|---|
| Falsification of a bank receipt by a private individual (Art. 172 ¶2) | Prisión correccional, medium to maximum (4 years, 2 months + 1 day – 6 years) | Up to ₱1 000 000 |
| Same, but by a public officer (Art. 171) | Prisión mayor, medium to maximum (8 years + 1 day – 12 years) | Up to ₱2 000 000 |
| If complexed with estafa (Art. 315 & 48) | Penalty for estafa, raised to next higher period because of complexity (amount-dependent; could reach reclusión temporal) | Fine equal to amount defrauded plus incremental penalties |
| Electronic or digital receipt (R.A. 8792 §36) | 6–12 years | ₱100 000 – ₱1 000 000 (court’s discretion) |
| Computer-related forgery (R.A. 10175 §4(1)) | One degree higher than the underlying felony (thus up to reclusión temporal if Art. 172 is the base) | Same fine range “as may be provided by law” |
| Bank insiders (R.A. 8791 §36) | 6–12 years | Up to ₱2 000 000, plus removal & perpetual disqualification |
Notes:
- Subsidiary imprisonment applies when the fine cannot be paid (Art. 39 RPC, as amended).
- Penalties are still governed by the Indeterminate Sentence Law—minimum is within the next lower degree.
4. Ancillary criminal laws often implicated
- Anti-Money Laundering Act (R.A. 9160 §14) – making a false statement to deceive AMLC is punished by 4–14 years and a fine up to ₱3 000 000.
- P.D. 1689 – if falsification is committed by a syndicate (≥ 5 persons) or on a large scale (≥ 20 victims) in relation to estafa, the penalty is reclusión temporal to reclusión perpetua.
- BSP Circular No. 1108 (2020) – mandates robust controls on electronic receipts; violations expose directors and officers to BSP administrative sanctions on top of criminal prosecution.
5. Jurisprudence snapshot
| Case | G.R. No. | Ratio |
|---|---|---|
| People v. Po Go & Uy Khay Lian (1967) | L-20763 | Deposit slips are commercial documents; private individuals who falsify them incur Art. 172 ¶2. |
| People v. Relato (1990) | 79297 | Making fictitious credit memos to hide cash shortages is falsification; when used to obtain money, complexed with estafa. |
| People v. Dizon (1988) | 62085 | A bank cashier of a GOCC is a public officer; falsification attracts Art. 171 with heavier penalty. |
| Spouses Sta. Maria v. People (2015) | 195197 | Presentation of a forged deposit slip in a civil case constitutes use of a falsified commercial document, itself punishable under the last clause of Art. 172. |
| Rowena Llenado v. People (2022) | 257598 | Electronic screenshots of mobile-banking receipts forged via image editing fall under R.A. 10175, one degree higher penalty. |
6. Prescription and venue
Prescriptive period – depends on the principal penalty actually imposable:
- Prisión correccional ⇒ 10 years (Art. 9 & Art. 90 RPC).
- Prisión mayor or higher ⇒ 15 years. The period is counted from the date of falsification or, for “use” cases, from the date the falsified receipt was used.
Venue – offense may be tried where the falsification was executed or where the falsified receipt was introduced or intended to be used (Rule 110 §15, Rules of Court).
7. Civil and administrative fallout
- Civil liability – falsifier must indemnify the bank or any injured depositor for actual, moral, and exemplary damages (Art. 100 RPC; Arts. 19–21, Civil Code).
- Labor law – dismissal for serious misconduct and loss of trust is valid; Maybank Philippines v. Juen (G.R. 221057, 2018).
- BSP sanctions – fines, suspension of directors/officers, potential closure of unsafe institutions under R.A. 11211 (New Central Bank Act).
8. Defenses and mitigating factors
- No falsification if alteration is immaterial – changes that do not affect the meaning or legal effect of the receipt are not punishable.
- Good-faith dispute over amount does not excuse forged alteration.
- Voluntary desistance may mitigate penalty but rarely applies once document is forged.
- Plea to lesser offense – courts often allow plea to Art. 172 ¶3 (private document) if prosecution cannot prove commercial character.
9. Compliance tips for banks and businesses
- Dual verification of all receipts, physical or digital, before release of funds.
- Secure receipt paper (watermarks, UV fibers); employ PKI-based digital signatures for e-receipts.
- Real-time audit analytics to flag duplicate or out-of-sequence receipt numbers.
- Mandatory leave policy for cash-handling staff—recognized by jurisprudence as a fraud-deterrence tool.
- Regular legal training on Art. 171–172, R.A. 8792, and R.A. 10175.
10. Key take-aways
- Falsifying a bank receipt is almost always treated as falsification of a commercial document (Art. 172 ¶2).
- Penalties now reach up to six years’ imprisonment and ₱1 million fine; higher if the offender is a public officer, if the act is cyber-enabled, or if estafa or money-laundering is involved.
- Intent to gain or prejudice is unnecessary for consummation, although using the forged receipt to defraud raises the stakes dramatically.
- Electronic receipts are squarely covered by R.A. 8792 and enhanced by the Cybercrime Act, imposing stiffer penalties.
- Beyond imprisonment and fines, civil liability, administrative sanctions, and reputational damage often inflict the harsher blow.
This article is informational and does not constitute legal advice. For actual cases, consult Philippine counsel or the Bangko Sentral ng Pilipinas for regulatory guidance.