G.R. No. 132601 - Echegaray vs. Secretary of Justice

Case Digest (G.R. No. 132601)
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Facts:

Parties and Background

Floro T. Tadena (petitioner) was then the Municipal Mayor of Sto. Domingo, Ilocos Sur.
The Sangguniang Bayan (SB) of Sto. Domingo was the local legislative body involved.
Rodel M. Tagorda was the Secretary of the Sangguniang Bayan at the time.

Sequence of Events

On October 17, 2001, Tadena wrote a letter requesting the creation of the position of Municipal Administrator.
On December 10, 2001, the Sangguniang Bayan adopted the First Version of the municipal ordinance (No. 2001-013) for the 2002 budget; paragraph (a) of the 4th Whereas Clause conditioned creation of the Municipal Administrator position on satisfaction of office needs via supplemental budgets and implementation of the mandatory 5% salary increase for 2001.
Tadena vetoed the First Version, stating the conditions were unrealistic, and requested deletion of those conditions based on a prior conference agreement.
On January 11, 2002, the Sangguniang Bayan passed the Second Version of the ordinance. Paragraph (a) now stated that the Municipal Administrator position “shall not be created unless 2% of the Mandatory 5% Salary Increase for 2002 be implemented.”
On January 14, 2002, the SB Secretary Tagorda transmitted the Second Version to Tadena for approval.
On January 23, 2002, the Office of the Municipal Mayor returned the ordinance with Tadena’s signature, but the first page was substituted and paragraph (a) altered to read: “The position ‘MUNICIPAL ADMINISTRATOR’ shall be created and the 2% of the Mandatory 5% Salary Increase for 2002 be implemented.”
On January 25, 2002, the Sangguniang Bayan issued Resolution No. 007 noting the alteration and deleted paragraph (a) from the ordinance.
The First and Second Versions were never implemented, remained in records; a Final Version was enacted without the alleged falsified changes.

Criminal Proceedings

SB Secretary Tagorda filed a complaint for falsification of public document against Tadena before the Office of the Ombudsman.
Initially dismissed but reversed on motion for reconsideration on August 28, 2002, leading to the filing of Information on July 4, 2014.
Tadena pleaded not guilty on arraignment.
At pre-trial, the parties stipulated Tadena was a public officer and Tagorda was the Sangguniang Bayan Secretary.
The main issues proposed: whether Tadena changed paragraph (a) of the 4th Whereas Clause altering its meaning; and whether he falsified the ordinance dated January 11, 2002.
On September 15, 2016, the Sandiganbayan (SB) found Tadena guilty beyond reasonable doubt of falsification of public document.
Reconsideration was denied on December 7, 2016.
Tadena filed a Petition for Review on Certiorari before the Supreme Court raising multiple grounds, including alleged inordinate delay, lack of criminal intent, authorization of changes by Sangguniang Bayan, and issues on document genuineness.

Issues:

Was there inordinate delay in the prosecution violating Tadena’s right to speedy disposition of the case?
Did the SB err in convicting Tadena beyond reasonable doubt of falsification of public document under Article 171, paragraph 6 of the Revised Penal Code?
Was the document falsified a genuine public document?
Were the changes made by Tadena done with the concurrence of the majority of the Sangguniang Bayan members?
Did Tadena act in good faith and with no criminal intent?
Should the mitigating circumstance of voluntary surrender have been appreciated?
Were the proper penalties imposed?

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 132601)
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