Case Digest (G.R. No. 212656-57)
Facts:
Mayor Amado Corpuz, Jr. v. People of the Philippines and Sandiganbayan, G.R. Nos. 212656-57, November 23, 2016, Supreme Court Third Division, Perez, J., writing for the Court.
Petitioner Amado Corpuz, Jr., then Municipal Mayor of Cuyapo, Nueva Ecija, was criminally charged before the Sandiganbayan with two counts of falsification of public document under Article 171(4) of the Revised Penal Code for certifying in two marriage certificates that he personally solemnized the marriages of Alex Pascual and Esperanza Arizabal (December 18, 2009) and Manny Asuncion and Dina Lumanlan (October 28, 2009), when the prosecution alleged that Thelmo O. Corpuz, Sr., the Municipal Civil Registrar, actually performed the solemnizations. Trial on the Informations ensued before the Sandiganbayan with the prosecution presenting five witnesses (including complainant Arsenio Flores, photographers Jorge Lazaro and Honorato Tolentino, and rebuttal witness Thelmo Corpuz, Sr.) and the defense presenting three witnesses (including petitioner and the two husbands) plus documentary evidence (marriage certificates, invitation cards, photos, joint affidavits of cohabitation and confirmation).
At trial the prosecution's witnesses testified they observed ceremonies in front of Thelmo O. Corpuz, Sr., and produced photographs and invitation cards showing the couples before the Municipal Registrar; Thelmo O. Corpuz, Sr. later testified that he had pleaded guilty before the Municipal Trial Court (MTC) to usurpation of official functions relating to the two ceremonies and was sentenced on July 15, 2013. The defense witnesses — the two husbands and petitioner — testified that the actual solemnizations took place at the Mayor’s office and that petitioner officiated; documentary evidence signed by petitioner was also presented. The Sandiganbayan, relying on the prosecution testimony and exhibits, found petitioner guilty on February 27, 2014 and sentenced him; its denial of petitioner’s motion for reconsideration was embodied in a May 23, 2014 Resolution.
Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court to the Supreme Court, contesting the Sandiganbayan’s factual findings, the admission of photocopies and secondary eviden...(Subscriber-Only)
Issues:
- Whether petitioner was proven guilty beyond reasonable doubt of two counts of falsification of public document under Article 171(4) of the Revised Penal...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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