Case Summary (G.R. No. 245931-32)
Procedural Antecedents
Arnaldo Partisala, along with his co-accused, faced charges under Criminal Case Nos. 25674 and 25675 for violations of the Anti-Graft and Corrupt Practices Act as well as Falsification of Public Documents. The accusations stemmed from the alleged falsification of two resolutions purportedly enacted by the Sangguniang Bayan, which would provide the Mayor with emergency powers that led to IBC conducting quarrying operations without the necessary permits.
Factual Antecedents
On June 16, 1996, a resolution was passed by the Sangguniang Barangay of Naslo requesting the IBC to rechannel the Tigum River. Following this, the Municipal Development Council adopted a similar resolution, ultimately leading to the Sangguniang Bayan enacting two resolutions on June 21, 1996. However, the resolutions were later claimed to be falsified, leading to the prosecution against all involved, including Partisala, who as Municipal Vice Mayor, played a pivotal role in their enactment.
Ruling of the Sandiganbayan
On November 23, 2018, the Sandiganbayan found Partisala guilty of violating Section 3(e) of Republic Act No. 3019 and Falsification under Article 171 of the Revised Penal Code. The court determined that Partisala's involvement constituted both participation in the legislative act and the false representation of that act, leading to unwarranted advantages for IBC.
Issues on Appeal
The central issues raised by Partisala included whether his actions in allowing the Mayor to negotiate with IBC constituted an unwarranted benefit and whether he participated in the falsification of the Minutes of the Regular Session.
Appellate Court's Ruling
The appellate court upheld the findings of the Sandiganbayan. It affirmed that Partisala's acts exhibited evident bad faith and manifest partiality, thereby justifying the charges against him. The court dismissed his arguments regarding the alleged failure of the prosecution to prove the authenticity of the minutes, stating that the testimonies provided were credible and corroborated by evidence.
Penalty Modification
While the appellate court confirmed Parti
...continue readingCase Syllabus (G.R. No. 245931-32)
Case Overview
- This case involves the appeal of Arnaldo Partisala against the November 23, 2018 Decision and February 14, 2019 Resolution of the Sandiganbayan.
- Partisala was found guilty beyond reasonable doubt of violating Section 3 (e) of Republic Act No. 3019, known as the "Anti-Graft and Corrupt Practices Act," and for Falsification of Public Document under Article 171 of the Revised Penal Code (RPC).
- The case pertains to actions taken during Partisala's tenure as the Municipal Vice Mayor of Maasin, Iloilo.
Procedural Antecedents
- Partisala was charged along with several other public officers and a private individual, Helen Edith Lee Tan, for their roles in two separate criminal cases.
- The first information (Criminal Case No. 25674) alleged that the accused conspired to make it appear that a resolution authorizing Mayor Mondejar to exercise emergency powers was validly enacted.
- The second information (Criminal Case No. 25675) involved the false certification of the Minutes of the Sangguniang Bayan's regular session, wherein it was claimed that specific resolutions were deliberated upon when they were not.
Factual Antecedents
- On June 16, 1996, the Sangguniang