Case Digest (G.R. No. 141617)
Facts:
In Sevilla v. People, G.R. No. 194390, decided on August 13, 2014, petitioner Venancio M. Sevilla, then newly elected councilor of Malabon City, was charged under Article 171(4) of the Revised Penal Code (RPC) for making an untruthful statement in his Personal Data Sheet (PDS) dated July 2, 2001. Specifically, in response to the question whether any criminal case was pending against him, Sevilla marked “no,” despite the pendency of Criminal Case No. 6718-97 for assault before the Metropolitan Trial Court of Malabon City, Branch 55. During trial in the Sandiganbayan (Criminal Case No. 27925), Sevilla admitted signing the PDS without verifying its content, attributing its preparation to his staff member, but asserted he lacked intent to falsify. The Office of the Ombudsman had earlier found him administratively liable for dishonesty and falsification, resulting in dismissal from service, and this finding was affirmed by this Court in *Sevilla v. Gervacio* (G.R. No. 157207, June 23...Case Digest (G.R. No. 141617)
Facts:
- Antecedent Facts
- Venancio M. Sevilla, former councilor of Malabon City, was charged by Information dated July 2, 2001 with falsification of public document under Article 171(4) of the Revised Penal Code (RPC).
- The Information alleged that Sevilla willfully made an untruthful statement in his Personal Data Sheet (PDS) by marking “no” to the existence of any pending criminal case against him, despite a pending assault case in Criminal Case No. 6718-97.
- Proceedings Before the Sandiganbayan
- Sevilla pleaded not guilty and trial ensued. The prosecution presented evidence showing he signed the PDS without verifying entries prepared by his staff member, Editha Mendoza.
- The Sandiganbayan found all elements of falsification of public documents but ruled that Sevilla acted without malice, convicting him instead of reckless imprudence resulting in falsification under Article 365 of the RPC. It imposed four months of arresto mayor to two years, ten months, and twenty-one days of prision correccional.
- Post-Decision and Recourse
- Sevilla’s motion for reconsideration before the Sandiganbayan was denied on October 22, 2010.
- He filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, challenging his conviction on the ground of variance between the charged intentional felony and the proven quasi-offense.
Issues:
- Whether a defendant charged with the intentional felony of falsification of public documents under Article 171(4) of the RPC may be validly convicted of the quasi-offense of reckless imprudence resulting in falsification under Article 365 of the RPC, given the variance between the Information and the proof.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)