G.R. No. 212656-57 - Corpuz, Jr. vs. People

Petitioner Mayor Amado Corpuz, Jr., in his capacity as the Municipal Mayor of Cuyapo, Nueva Ecija, was indicted for two counts of falsification of public document under Article 171, paragraph 4 of the Revised Penal Code.
The case arose from two separate Informations:

Criminal Case No. SB-12-CRM-0171 – related to the marriage of Manny Asuncion and Dina Lumanlan.
Criminal Case No. SB-12-CRM-0172 – related to the marriage of Alex Pascual and Esperanza Arizabal.

In both cases, petitioner was accused of falsifying the marriage certificates by certifying that he solemnized the marriages when, in fact, the actual solemnizing officer was Thelmo O. Corpuz, Sr., then the Municipal Civil Registrar.

Held on October 28, 2009, at Cuyapo Town Hall, with the ceremony’s timing specified around 9:30 in the morning.
Evidence included the invitation for the nuptials, and documentary evidence supported by the testimony of Jorge N. Lazaro (a freelance photographer) who witnessed the ceremony at a local venue.

Held on December 18, 2009, at the Municipal Hall, around 9:00 in the morning.
Testimonies of Arsenio Flores, a principal sponsor present during the wedding, and Honorato M. Tolentino (the groom’s brother-in-law and photographer for the event) were presented.

In both scenarios, the marriage certificates bore the signature of petitioner as the solemnizing officer despite claims that he did not officiate the marriages himself.
Additional documentary evidence was introduced including photographs, invitation cards, and joint affidavits executed by the couples attesting that petitioner was the one who solemnized their marriage.
Petitioner also testified in his defense by asserting:

He was present in his office and actually solemnized both marriages.
The signatures on the certificates, as well as affidavits by the couples, were reflective of the truth.
He emphasized his long-standing experience as mayor, asserting that the authority to solemnize marriage cannot be delegated.

Witness Arsenio Flores testified that he personally witnessed the wedding ceremonies being solemnized by Thelmo O. Corpuz, Sr. and noted inconsistencies such as the immediate issuance of the certificates.
Honorato M. Tolentino corroborated by testifying to his photographic presence during the wedding of Alex Pascual and Esperanza Arizabal.
Jorge N. Lazaro provided an account for the Asuncion-Lumanlan wedding, noting that the ceremony was conducted by Thelmo O. Corpuz, Sr.
Thelmo O. Corpuz, Sr. presented rebuttal evidence confirming that he was the one who conducted the ceremonies and even admitted to having pleaded guilty in a prior related usurpation of official functions case.

Petitioner testified that he personally solemnized the marriages.
The couples themselves, Alex Y. Pascual and Manny M. Asuncion, affirmed in their testimonies and joint affidavits that petitioner was the officiating officer.
Petitioner contended that the presumption of authenticity of public documents should prevail over the testimonies which he alleged were tainted by political motivations and inconsistencies.

The Sandiganbayan (SB) trial court rendered a Decision on February 27, 2014, finding petitioner guilty beyond reasonable doubt for two counts of falsification of public document.
The SB sentenced him to imprisonment – four years and one day of prision correccional as minimum and eight years of prision mayor as maximum for each count—and imposed a fine.
Petitioner’s motions for reconsideration and supplemental arguments were denied through a subsequent resolution dated May 23, 2014.
Petitioner then elevated the matter by filing a Petition for Review on Certiorari before the Supreme Court.

Whether the prosecution was able to prove beyond reasonable doubt that petitioner committed falsification of public document by:

Certifying the marriage certificates with false particulars, namely, asserting that he solemnized marriages which were in fact conducted by Thelmo O. Corpuz, Sr.
Taking advantage of his official position as Municipal Mayor in the supposed falsification.

Whether the evidence, particularly the conflicting testimonies and documentary exhibits (invitation cards, photographs, and affidavits), was sufficient to overcome the presumption of regularity and authenticity of official documents.
Whether the trial court erred in its evidentiary rulings, including the admission of photocopies and secondary evidence, as alleged by petitioner.
Whether the credibility assessments of the witnesses (both prosecution and defense) were correctly made and applied to conclude the guilt or innocence of the petitioner.
Whether the issues regarding the weight and deployment of circumstantial evidence have been improperly resolved, given the competing narratives of the parties regarding the actual performance of the solemnization.