Case Summary (G.R. No. 174730-37)
Case Background
Mayor Amado Corpuz, Jr. was charged with two counts of Falsification of Public Document under Article 171, paragraph 4 of the Revised Penal Code. The accusations stem from alleged certifications by the petitioner which indicated he solemnized marriages that were actually officiated by Thelmo O. Corpuz, Sr., the Municipal Civil Registrar, during the periods of October 28, 2009, and December 18, 2009.
Procedures and Evidence Presented
In the trials, the petitioner pleaded not guilty, which led to testimonies from five prosecution witnesses and three defense witnesses. The main issue discussed during trial was the credibility of testimonies concerning who solemnized the marriages.
The prosecution's witnesses included Arsenio Flores and Honorato M. Tolentino, who testified to witnessing the ceremonies officiated by Thelmo Corpuz, Sr. Jorge N. Lazaro confirmed the similar discrepancies for the marriage of Manny Asuncion and Dina Lumanlan, stating the actual officiant was also Thelmo Corpuz, Sr. Thelmo Corpuz, Sr. later testified against the petitioner, reflecting the complexity of the relationships and political dynamics between the individuals involved.
In contrast, the defense presented testimonies from the couples involved, who maintained that Mayor Corpuz officiated their marriages, thus supporting the legitimacy of his actions.
Legal Framework
The legal basis for the charges rested primarily on Article 171 of the Revised Penal Code, which details the conditions under which the falsification of official documents can occur, notably requiring proof that the statements made were untruthful, and that the accused made such statements while being aware of their falsity.
Findings and Rulings of the Sandiganbayan
The Sandiganbayan found Corpuz guilty beyond reasonable doubt, detailing that he had taken advantage of his official position to certify the marriages incorrectly. The court emphasized the violation of public faith, holding that the falsification did not necessitate proving that the petitioner aimed to gain personally or injure others.
Appeal and Controversy
In his appeal, Mayor Corpuz challenged the credibility of prosecution witnesses and argued against the evidentiary rulings of the Sandiganbayan, claiming that the trial court allowed photocopies of documents without proper foundation and that it failed to adequately consider the explicit testimonies of the couples, who insisted he officiated their m
...continue readingCase Syllabus (G.R. No. 174730-37)
Overview of the Case
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioner, Mayor Amado Corpuz, Jr., is contesting the Decision and Resolution of the Sandiganbayan (SB) in Criminal Case Nos. SB-12-CRM-0171 and SB-12-CRM-0172.
- The SB found the petitioner guilty beyond reasonable doubt of two counts of Falsification of Public Document as defined under Article 171, paragraph 4 of the Revised Penal Code (RPC).
Factual Background
- The petitioner served as the Municipal Mayor of Cuyapo, Nueva Ecija, and was indicted for falsifying marriage certificates.
- The first charge (CRIM. CASE NO. SB-12-CRM-0171) involved the marriage certificate of Manny Asuncion and Dina Lumanlan, where the petitioner falsely certified he solemnized their marriage.
- The second charge (CRIM. CASE NO. SB-12-CRM-0172) involved the marriage certificate of Alex Pascual and Esperanza Arizabal, where the petitioner similarly misrepresented himself as the solemnizing officer.
Trial Proceedings
- The petitioner pleaded not guilty, leading to a trial where five prosecution witnesses and three defense witnesses testified.
- Key testimonies included:
- Arsenio Flores, a wedding sponsor, who stated he witnessed the actual wedding solemnization by Thelmo O. Corpuz, Sr., not the petitioner.
- Honorato M. Tolentino corroborated Flores' account regarding the Pascual-Arizabal wedding, noting he also observed that Thelmo O. Corpuz, Sr. officiated the ceremon