G.R. No. 93833 - Ramirez vs. Court of Appeals

Feliciano Palad Legaspi, Sr. was the duly elected Municipal Mayor of Norzagaray, Bulacan from 2007 to 2013.
Legaspi reassigned Yolanda C. Ervas, Municipal Budget Officer, to the Norzagaray Public Market.
Ervas filed an administrative complaint alleging oppression and grave abuse of authority against Legaspi, arguing that the reassignment was improper and detrimental to her rank and salary.
On August 31, 2012, the Office of the Deputy Ombudsman for Luzon decided to suspend Legaspi for six months and one day for oppression or grave abuse of authority.
The Department of the Interior and Local Government (DILG) Region III was instructed to implement the suspension.
The suspension order was served on December 12, 2012, through Silangan Rivas, the Municipal Human Resource Management Officer, who accepted the suspension order on Legaspi’s behalf.
Vice Mayor Rogelio P. Santos, Jr. was sworn in as acting mayor following the suspension.

Despite suspension from December 12, 2012 to June 13, 2013, Legaspi solemnized 37 marriages and issued a mayor’s permit to Wacuman Incorporated.
These acts were done under the pretense of official municipal powers although Legaspi was suspended and not legally authorized to perform mayoral functions.
The Office of the Special Prosecutor (OSP) filed 38 Informations against Legaspi for usurpation of official functions under Article 177 of the Revised Penal Code.
Documentary evidence included 37 certified Philippine Statistics Authority (PSA) marriage certificates and a certified copy of the mayor’s permit.
Witnesses, including municipal officials and personnel, testified to Legaspi’s involvement in authorizing these acts during his suspension.
Legaspi denied knowledge or signing of the documents, questioned the authenticity of the certificates, and argued that he could not have performed the acts due to his suspension.

On May 11, 2018, the Sandiganbayan rendered a decision finding Legaspi guilty beyond reasonable doubt of usurpation of official functions under Article 177 of the Revised Penal Code.
It held that Legaspi was not entitled to exercise powers as municipal mayor during his suspension and that his acts of solemnizing marriages and issuing permits under pretense of office were unlawful.
The decision took into account the documentary evidence, witness testimonies, and the acknowledgment of Legaspi’s legal counsel regarding receipt of the suspension order.
Legaspi’s motion for reconsideration was denied by the Sandiganbayan in a September 18, 2018 resolution.
The Sandiganbayan rejected claims of forgery and improper service of the suspension order.

Legaspi filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, questioning the sufficiency and admissibility of the prosecution’s documentary evidence.
He also argued defective service of the suspension order and claimed the prosecution failed to prove that the signatures on documents were his.
The Office of the Special Prosecutor opposed the petition, asserting Legaspi’s guilt was clearly established.

Whether Feliciano Palad Legaspi, Sr. is guilty of 38 counts of usurpation of official functions under Article 177 of the Revised Penal Code for acting with official capacity while under suspension.

Whether the documentary evidence presented by the prosecution, including marriage certificates and mayor’s permit, were properly authenticated and admissible.

Whether the service of the suspension order on Legaspi complied with legal requirements.

Whether the claim of forgery regarding signatures on the questioned documents merits consideration.