G.R. No. 209830 - Mitsubishi Motors Phils. Corp. vs. Bureau of Customs

Paulino S. Ong was appointed Officer-in-Charge (OIC) Mayor of Naga, Cebu on April 16, 1986, then elected Mayor from 1988 to 1998.
On June 1, 1994, Ong issued permanent appointments to Rosalio S. Galeos (Construction and Maintenance Man) and Federico T. Rivera (Plumber I) in the Municipal Engineer’s Office.

In 1993 SALNs, Galeos answered “No” to being related within the fourth civil degree to anyone in government; Rivera wrote “n/a.”
In SALNs for 1994–1996, both Galeos and Rivera either left the relatives-in-government question blank or answered “No.”
Ong administered the oaths on all these SALNs.
In a June 1, 1994 letter to the CSC, Ong and an HR officer certified that all requirements—including Section 79 (nepotism prohibition) of the Local Government Code—were complied with in making the appointments.

On October 1, 1998, the Sangguniang Bayan of Naga filed a complaint with the Ombudsman alleging dishonesty, nepotism, Code of Conduct violations and falsification of public documents.
On August 11, 2000, criminal charges under Article 171(4) of the Revised Penal Code (RPC) were authorized: eight counts against Ong; four counts against Galeos; informations in Criminal Case Nos. 26181–26189.
In pre-trial stipulations, petitioners admitted Ong’s kinship with Galeos (first cousins) and Rivera (fourth-degree affinity) and the authenticity of the documents, except one certification exhibit.
Trial testimonies established family relationships and petitioners claimed ignorance of those relationships when executing or administering the SALNs.

On August 18, 2005, the Sandiganbayan convicted Ong and Galeos in Criminal Cases 26181, 26183, 26186, 26187, 26189 and convicted Ong and Rivera in 26182, 26184, 26185; acquitted Ong in 26188; imposed indeterminate sentences and fines.
Motions for reconsideration were denied on August 28, 2006; charges against deceased Rivera were dismissed.
Petitioners appealed to the Supreme Court alleging (a) no narration of facts, (b) lack of intent and good faith, (c) undue reliance on a sole witness, and (d) improper liability of an oath-administering officer.

Do the SALNs’ answers regarding relatives and the June 1, 1994 certification constitute “untruthful statements in a narration of facts” under Article 171(4), RPC?
Were petitioners under a legal obligation to disclose the truth and did they take advantage of their official positions?
Can ignorance of the family relationship or good-faith belief negate the element of intent in falsification?
Can Ong, as the officer administering oaths, be held liable as a co-conspirator in falsification?
Was the prosecution’s evidence, including the testimony of a sole witness, sufficient to establish guilt beyond reasonable doubt?