Case Summary (G.R. No. 223572)
Facts of the Case
The respondent court summarized the facts leading to the conviction of Atty. Manzanaris. He was responsible for the custody of all Court records, including those related to Criminal Case No. 299 against Geronimo Borja for malversation of public funds. When Manzanaris discovered that the original Certificate of Title No. 877 was missing from the Register of Deeds of Basilan, he ordered a subordinate to deliver the owner’s copy to Borja for administrative reconstitution, which was done without a written order from the presiding judge. Borja subsequently signed a receipt acknowledging the title’s delivery. Despite successful reconstitution of the title in November 1974, the title was never returned to the court.
Legal Grounds for Conviction
Manzanaris was originally found guilty under Article 226, paragraph 2 of the Revised Penal Code concerning the removal, concealment, or destruction of documents. The Sandiganbayan imposed penalties including imprisonment, a fine, and disqualification from holding public office. The court viewed his actions as a breach of duty despite his claims of good faith.
Petitioner’s Defense
In his defense, Manzanaris asserted that his motivations were lawful and aimed at preserving the State's interests by ensuring the validity of the property bond. He contended that the removal of the title was not prompted by criminal intent or illicit purpose, but rather by a desire to secure the document against loss, particularly after a fire had destroyed the court's records in 1975.
Standards of Criminal Liability
The core legal principle in question centers around the necessity of criminal intent for liability in infidelity in the custody of documents. The court held that a presumption of criminal intent typically arises from the commission of a criminal act; however, if the act in question does not constitute a crime or does not arise from illicit motives, then it cannot warrant a finding of guilt.
Judgement Reversal
After thorough deliberation, the court concluded that Manzanaris's actions were motivated by commendable objectives rather than criminal intent. Citing
...continue readingCase Syllabus (G.R. No. 223572)
Case Citation
- Case Reference: 212 Phil. 190 EN BANC
- G.R. No.: L-64750
- Date: January 30, 1984
Parties Involved
- Petitioner: Atty. Selso M. Manzanaris
- Respondents: People of the Philippines and Honorable Sandiganbayan
Background of the Case
- The case involves a petition for review of a decision rendered by the Sandiganbayan, which found the petitioner guilty of infidelity in the custody of documents under Article 226, paragraph 2 of the Revised Penal Code.
- The petitioner was sentenced to:
- An indeterminate penalty of 3 months and 11 days of arresto mayor to 1 year, 8 months, and 21 days of prision correccional.
- A fine of ₱500.00, with subsidiary imprisonment in case of insolvency.
- An additional penalty of 11 years and 1 day of temporary special disqualification.
- Payment of costs.
Facts of the Case
- Position of the Petitioner: Clerk of Court at the Court of First Instance of Basilan since 1963, responsible for the custody of all court records.
- Incident Overview:
- Involved Criminal Case No. 299 against Geronimo Borja for malversation of public funds.
- The property bond included a title covered by Certificate of Title No. 877, which was found missing from the Register of Deeds of Basilan.
- Petitioner ordered a subordinate to deliver the owner's copy of Certificate of Title No. 877 to Borja for administrative reconstitution, without a written order from the presiding judge.
- A receipt was signed by Borja upon receiving the title, acknowledging that it would be returned