Case Digest (G.R. No. 93842)
Case Digest (G.R. No. 93842)
Facts:
Hernando C. Layno v. The People of the Philippines and the Sandiganbayan, G.R. No. 93842, September 07, 1992, Supreme Court En Banc, Padilla, J., writing for the Court. The petition seeks review of the Sandiganbayan decision in Criminal Case No. 12955 dated 15 June 1990, which convicted petitioner of falsification of a public document under Article 171(4) of the Revised Penal Code.Petitioner, then mayor of Lianga, Surigao del Sur, appointed his son, Fernando Y. Layno, as meat inspector on 16 March 1980. The appointment form (Civil Service Form No. 35) bore the mayor’s signature twice — as appointing authority and as personnel officer — and was accompanied by a certification (Exhibit B) signed by petitioner stating that the appointee was not related to him within the third degree. The appointment package was received by the Civil Service Commission (CSC) Davao Regional Office on 17 May 1980, approved on 20 May 1980, and returned to the municipal office three days later. The appointee did not assume the post nor draw salary.
On 28 September 1988 petitioner was charged in the Sandiganbayan with falsification of a public document for certifying falsely that the appointee was not related to him within the third degree. At pre-trial (9 February 1989) petitioner admitted he was mayor on the date, had authority to appoint, appointed Fernando, and admitted Fernando was his legitimate son; he contested, however, that he did not sign or issue Exhibit B, and later asserted he revoked the appointment once told it violated nepotism rules.
At trial the prosecution’s main witness, Amando R. Pandi, Jr., municipal secretary and designated personnel officer, identified the signature on Exhibit B as petitioner’s; the Sandiganbayan also compared the signature with other admitted genuine signatures of petitioner. On 15 June 1990 the Sandiganbayan, in Criminal Case No. 12955, found petitioner guilty beyond reasonable doubt and imposed an indeterminate sentence (minimum: 2 years, 4 months, 1 day; maximum: 8 years, 1 day) and a fine of P2,500. Petitioner filed a petition for review on certiorari to the Supreme Court (Rule 45), contending (1) the Sandiganbayan failed to consider his defenses, (2) the prosecution evidence was insufficient, and (3) the Court failed to apply proof beyond reasonable doubt.
Issues:
- Was the prosecution witness competent to identify and testify as to the petitioner’s signature on the questioned certification?
- Did the petitioner have a legal obligation to disclose his true relationship with the appointee in the certification required by the civil service rules (i.e., was there an obligation to tell the truth in Exhibit B)?
- Can the petitioner’s asserted good faith, withdrawal of the appointment, or ignorance of the nepotism law absolve him of criminal liability for falsification?
- Was the evidence sufficient to establish guilt beyond reasonable doubt for falsification of a public document under Article 171(4) of the Revised Penal Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)