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Valencia Court Dismisses Diploma Forgery Case Against José María Ángel as Time-Barred

The ruling classifies the alleged 1983 forgery as an instantaneous offense that has prescribed, leaving only potential appeals.

Overview

  • Examining Court No. 4 of Valencia ordered a definitive dismissal of the falsedad documental case, declaring any criminal liability extinguished by prescription.
  • The complaint by the civil servants’ union Manos Limpias targeted a purported 1983 diploma in archivistics and library science listed in Ángel’s Diputación de Valencia file.
  • The Universitat de València does not recognize that credential and says the program did not begin until 1990, a contradiction cited in the case materials.
  • The judge cited case law and noted the offense prescribes regardless of whether Article 390 or 392 of the Penal Code applies, stating the facts would have been time-barred at least 30 years ago.
  • The order was notified to the parties and can be challenged via a motion for reconsideration or appeal, while Ángel had already resigned in July following Antifraud findings and was briefly hospitalized days later.