Facts:

In the case of Felipe Fajelga vs. Hon. Romeo M. Escareal, Hon. Conrado M. Molina, and Hon. Ramon V. Jabson (G.R. Nos. 61017-18), decided on November 14, 1988, petitioner Felipe Fajelga challenged his conviction for falsification of public documents and infidelity in the custody of documents by the Sandiganbayan. The events began on November 5, 1979, when Serenico Ablat executed a Deed of Absolute Sale for a used Kawasaki motorcycle, selling it for P8,500 to the Provincial Government of Batanes, represented by Provincial Engineer Telesforo Castillejos. Fajelga, who was the motorcycle's registered owner having purchased it in 1978 for P5,900, was working as a driver-messenger in the Office of the Provincial Auditor. However, the sale to the provincial government never materialized as the new Provincial Auditor, Elena Alcantara, deemed the motorcycle impractical for her use after her predecessor's resignation. As a result, the sale was cancelled, and Alcantara later gave th

Facts:

1. Transaction Background: On 5 November 1979, Serenico Ablat signed a Deed of Absolute Sale for a used Kawasaki motorcycle for P8,500.00 in favor of the provincial government of Batanes, represented by Provincial Engineer Telesforo Castillejos. The motorcycle was registered in the name of petitioner Felipe Fajelga, who had purchased it in 1978 for P5,900.00.
2. Purpose of Sale: The sale was intended for the use of then Provincial Auditor Felix Balisi, as per a Purchase Request signed by Castillejos. However, the sale was cancelled after Balisi resigned, and the new Provincial Auditor, Elena Alcantara, deemed the motorcycle impractical for her use.
3. Cancellation and Fire: The cancelled vouchers and supporting documents were given to Fajelga, who allegedly placed them in a cabinet in the Provincial Auditor's office. The office was later destroyed by fire, and the documents were lost.
4. Criminal Charges: Fajelga, Castillejos, and Ablat were charged with violating the Anti-Graft and Corrupt Practices Act (Republic Act 3019) but were acquitted of graft charges. Fajelga was convicted of Falsification of Public Document (Criminal Case No. 3690) and Infidelity in the Custody of Documents (Criminal Case No. 3691).
5. Modification of Conviction: On 18 June 1982, the Sandiganbayan modified the conviction in Criminal Case No. 3690 to Falsification through Reckless Imprudence, reducing the penalty. The conviction in Criminal Case No. 3691 was upheld.

Issue:

1. Whether petitioner Fajelga can be convicted of Falsification under Article 171(2) or (4) of the Revised Penal Code, despite not being a party to the Deed of Absolute Sale or impersonating anyone.
2. Whether petitioner's conviction under Article 171(2) violates his constitutional right against double jeopardy, as he was tried under an information charging him under Article 171(4).
3. Whether the petitioner can be convicted of Falsification without proof of malicious intent to injure a third person or material damage to the government.
4. Whether petitioner's conviction for Infidelity in the Custody of Documents is valid, given that the documents were not officially entrusted to him and were deemed "scraps of paper" after cancellation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)