Case Digest (G.R. No. 12262)
Facts:
This case arises from Criminal Case No. SC-6712 filed by the Office of the Ombudsman for Luzon before the Regional Trial Court (RTC) Branch 26 in Sta. Cruz, Laguna, based on the affidavit-complaint of Manuel Torralba and two other members of the Sangguniang Barangay of Barangay Cabanbanan, Pagsanjan, Laguna. The accused, Laurinio Goma (Barangay Chairman) and Natalio Umale (Barangay Secretary), were charged with falsification of a public document under Article 171(2) of the Revised Penal Code (RPC). The complaint alleged that on or about September 24, 1995, the accused falsified a barangay resolution (Resolution No. T-95) by making it appear that a meeting was held with a quorum and that the Sangguniang Barangay passed a resolution allocating ₱18,000 to finance two officials’ attendance at a seminar in Zamboanga. However, the complainants testified that no quorum was present and no meeting was held on that date. The resolution bore the signatures of the accused and the official
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Case Digest (G.R. No. 12262)
Facts:
- Background and Parties
- Manuel Torralba and two other members of the Sangguniang Barangay of Brgy. Cabanbanan, Pagsanjan, Laguna, filed an affidavit-complaint.
- The Office of the Ombudsman for Luzon filed an Information for falsification of public document against petitioners Laurinio Goma (Barangay Chairperson) and Natalio Umale (Barangay Secretary).
- The complaint alleged falsification of a barangay resolution dated September 24, 1995, allocating PhP 18,000 to defray seminar expenses for the officials.
- Nature of the Alleged Offense
- The resolution claimed to be passed in a duly convened session of the sanggunian with all members present, motioned and seconded by specific kagawads.
- Petitioners allegedly caused it to appear that the resolution was passed despite the lack of quorum and no actual meeting held on September 24, 1995.
- The resolution bore the signatures of Laurinio (chairperson) and Natalio (secretary) and the official barangay seal.
- Trial Proceedings
- Petitioners pleaded not guilty.
- The prosecution presented witnesses (barangay kagawads Manuel Torralba, Armando Cabantog, and Ricaredo dela Cruz) who testified that no quorum was present and no session was held on September 24, 1995.
- The witnesses learned of the falsified resolution which purported to show unanimous approval by sanggunian members.
- On October 15, 1995, the sanggunian passed a special resolution stating that no session occurred on September 24, 1995.
- Defense of Petitioners
- Petitioners admitted signing the resolution but claimed it was merely a draft or proposal prepared in advance as per usual practice.
- They denied that the resolution was used as an enabling instrument for fund release.
- RTC's Decision
- The Regional Trial Court found the resolution to have the appearance of a genuine document, duly sealed and signed.
- It rejected the defense theory of the document being a mere draft as incredulous.
- Both petitioners were found guilty of falsification of public documents under Article 171(2) of the RPC and sentenced to prision correccional to prision mayor (minimum four years and two months to maximum eight years and two months).
- Court of Appeals' (CA) Decision
- The CA affirmed the RTC ruling in toto.
- The CA held that the resolution was a public document.
- It found the elements of falsification under Art. 171(2) of the RPC satisfied.
- The penalty imposed was proper.
- Petitioners’ Appeal to the Supreme Court (SC)
- The same issues were raised:
- Whether the resolution was a public document.
- Whether falsification occurred under Article 171(2) RPC.
- Whether the penalty was proper.
- Petitioners reiterated their defense that no quorum was present and the resolution was a mere draft.
- They denied affixing the barangay seal and alleged ill-feelings by complainant Torralba.
- Petitioners argued no benefit or prejudice arose from the resolution.
Issues:
- Whether the barangay resolution dated September 24, 1995 (Res. T-95) constitutes a public document under the law.
- Whether petitioners are guilty of falsification of a public document under Article 171(2) of the Revised Penal Code for causing it to appear that all sanggunian members participated in and unanimously approved the resolution when in fact no meeting was held.
- Whether the penalty imposed by the lower courts is proper and consistent with the law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)