G.R. No. 146217 - Bustillo vs. Sandiganbayan

The petitioner, Anuncio C. Bustillo, sought certiorari challenging the suspension orders issued by the Sandiganbayan.
The suspension order issued on August 28, 2000, suspended Bustillo from office for 90 days pending the resolution of Criminal Case No. 23076.

In 1995, the Office of the Special Prosecutor charged petitioner, then mayor of Bunawan, Agusan del Sur, along with his daughter Rowena Bustillo, with falsification of official documents under Article 171 of the Revised Penal Code.
The Information alleged that on or about September 6, 1991, petitioner used his official position to alter documents so that municipal funds amounting to ₱30,000.00 would appear as if expended for the purchase of lumber from Estigoy Lumber, whereas the lumber was actually purchased from Rowena Woodcraft (a single proprietorship owned by Rowena Bustillo).
The charge involved the falsification of three vouchers where the original payee’s name was erased and replaced with that of Estigoy Lumber, with Rowena Bustillo receiving the resulting payments.

In May 1998, the accused were arraigned and entered “not guilty” pleas in the Sandiganbayan.
Following the prosecution’s presentation of its evidence, the government moved for the suspension of petitioner under Section 13 of Republic Act No. 3019.
Although petitioner was granted an extension to comment on the motion for suspension, he ultimately failed to file his comment.
Consequently, on August 28, 2000, the Sandiganbayan ordered a 90-day suspension of Bustillo from office pending the outcome of the trial.

Bustillo argued that the Information was invalid because it did not allege essential elements such as the intention to gain, identification of the party benefited, or that the integrity of the document was compromised.
He further contended that the suspension was improper since the offense charged—falsification of official documents—falls under Title 4 of Book II of the Revised Penal Code, not Title 7 as required by Section 13 of RA 3019.
The Sandiganbayan, however, denied his motion for reconsideration on December 4, 2000, thereby upholding the suspension order.

Whether the Information filed against petitioner is valid despite alleged omissions regarding the element of gain, the identification of a benefiting party, or the tarnishing of a document’s integrity.
Whether the factual allegations satisfactorily fall under any of the modes of falsification prescribed in Article 171 of the Revised Penal Code.

Whether the suspension of petitioner from office pending trial is properly justified under Section 13 of Republic Act No. 3019.
Whether the charge of falsification, although classified under Title 4 of the Revised Penal Code, qualifies as an offense involving fraud upon government or public funds, thereby mandating suspension.