Case Digest (G.R. No. 194390)
Facts:
Venancio M. Sevilla v. People of the Philippines, G.R. No. 194390, August 13, 2014, Supreme Court First Division, Reyes, J., writing for the Court.
Petitioner Venancio M. Sevilla, a former councilor of Malabon City, was criminally prosecuted by information charging falsification of a public document under Article 171(4) of the Revised Penal Code (making untruthful statements in a narration of facts) for purportedly answering “no” to the question on his Personal Data Sheet (PDS) asking whether any criminal case was pending against him as of July 2, 2001. Sevilla pleaded not guilty and stood trial in the Sandiganbayan.
Concurrently, an administrative complaint (OMB-ADM-0-01-1520) was filed; the Office of the Ombudsman found Sevilla administratively liable for dishonesty and falsification of official document and dismissed him from the service, a finding that the Court later affirmed in Sevilla v. Gervacio (G.R. No. 157207).
At trial Sevilla admitted signing the PDS but explained he did not prepare it: his staff member Editha Mendoza allegedly typed the PDS from an earlier copy and delivered it to him for signature while he had no office; former councilor Edilberto G. Torres corroborated that staff used his office/typewriter and that Mendoza prepared the form. The prosecution nonetheless established that the PDS contained false or inconsistent entries (including the no answer to the pending-case question and other defects noted by the Ombudsman).
On February 26, 2009, the Sandiganbayan convicted Sevilla not of willful falsification under Article 171(4) but of a quasi-offense — “Falsification of Public Documents Through Reckless Imprudence” — treating the conduct as reckless imprudence resulting in falsification and sentencing him under Article 365 of the Revised Penal Code. The Sandiganbayan found absence of malicious intent but concluded Sevilla recklessly signed the PDS without verifying its contents; his motion for reconsideration was denied on October 22, 2010. Sevilla filed a petition for review on certiorari under Rule 45 before the Supreme C...(Pro-only)
Issues:
- May petitioner be convicted of reckless imprudence resulting in falsification of a public document (a quasi-offense under Article 365) when the Information charged only the intentional felony of falsification of public documents under Article 171(4) of the Re...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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