Case Digest (G.R. No. 68203)
Facts:
Meturogan L. Sarep v. Honorable Sandiganbayan, G.R. No. 68203. September 13, 1989, the Supreme Court En Banc, Padilla, J., writing for the Court. Petitioner Meturogan L. Sarep (hereafter petitioner) sought review of the Sandiganbayan's decision of 3 April 1984 in Criminal Case No. 4273 (People of the Philippines v. Meturogan Sarep y Lucman), which convicted him of falsification of a public document through reckless imprudence under Article 171, paragraph 4, in relation to Article 365, paragraph 1, of the Revised Penal Code. The information had been originally filed in the Court of First Instance of Cotabato and later transferred to the Sandiganbayan.On 19 January 1976 Director Kundo Pahm of the Bureau of Soils, Region XII, signed an appointment in favor of petitioner (Exh. C) but noticed an error in the civil service eligibility entry. He instructed acting personnel officer Usman Salic to prepare a corrected appointment (Exh. B), which Pahm signed and which was approved by the Civil Service Commission (CSC) Regional Office as "temporary." Exh. C was supposed to be cancelled. Petitioner’s appointment was renewed on 23 May 1977 (Exh. A) and again approved as temporary.
In March 1978 Director Pahm decided not to renew petitioner’s appointment because petitioner was not performing duties. Shortly thereafter Pahm received a xerox copy of the appointment (dated 30 December 1976, Exh. C) bearing erasures and superimpositions and showing CSC Central Office approval as "permanent." Petitioner refused to produce the original. Pahm filed a petition with CSC Central Office to recall or cancel the supposed permanent appointment.
An Information for falsification of official document was filed against petitioner on 21 December 1978 (Criminal Case No. 596, CFI of Cotabato) and the case was transferred to the Sandiganbayan by order dated 25 September 1981. After trial the Sandiganbayan, in a decision dated 3 April 1984, found petitioner guilty as principal of falsification of public documents through reckless imprudence and sen...(Subscriber-Only)
Issues:
- Whether the evidence supports a conviction of petitioner for falsification of a public document through reckless imprudence under Article 171(4) in relation to Article 365(1) of the Revised Penal Code.
- Whether petitioner’s asserted good-faith defenses (lack of intent to injure or to gain, and alleged prior erasures present before signing) negate criminal liability for falsification.
- Whether the penalty imposed by the Sandiganbayan was...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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