The Supreme Court affirmed the conviction of Arnaldo Partisala, former Vice Mayor of Maasin, Iloilo, for Falsification of Public Documents and violation of Section 3(e) of the Anti-Graft and Corrupt Practices Act. The Court found that Partisala manipulated official Sangguniang Bayan (SB) minutes to authorize a disadvantageous agreement with a private corporation, granting unwarranted benefits. This ruling underscores the importance of maintaining the integrity of public documents and holding public officials accountable for abusing their positions for personal gain. It reinforces the judiciary’s commitment to upholding transparency and preventing corruption in local governance.

The Corrupted Minutes: How a Vice Mayor’s Actions Led to Graft Charges

This case revolves around the rechanneling of the Tigum River in Maasin, Iloilo, and the alleged illegal quarrying activities that followed. The central question is whether Partisala, as the then Municipal Vice Mayor, participated in falsifying public documents and violated anti-graft laws by giving unwarranted benefits to a private corporation. The prosecution argued that Partisala, along with other officials, falsified the minutes of the Sangguniang Bayan (SB) session to make it appear that the SB had validly authorized the mayor to enter into a disadvantageous agreement with International Builders Corporation (IBC). This agreement allegedly allowed IBC to engage in massive quarrying activities without the necessary permits, causing damage to the environment and depriving the municipality of revenues.

The case began with resolutions from Barangay Naslo and the Municipal Development Council (MDC) requesting IBC to rechannel the Tigum River. Subsequently, the SB of Maasin enacted Resolution No. 30-A, endorsing the resolutions of Barangay Naslo and MDC, and Resolution No. 30-B, authorizing the mayor to use his emergency powers to negotiate with IBC for the rechanneling project. Based on these resolutions, the Municipality of Maasin entered into a Memorandum of Agreement (MOA) with IBC, allowing IBC to proceed with the rechanneling project in exchange for the surplus sand and gravel extracted from the river. Later, residents filed a complaint regarding the environmental damage caused by IBC’s quarrying activities.

An investigation revealed that the Municipality of Maasin had violated provincial ordinances by quarrying without the necessary permits. Criminal complaints were then filed against the accused, including Partisala, for Falsification of Public Documents and violation of Section 3 (e) of RA 3019. The Ombudsman-Visayas recommended filing Informations for Falsification and violation of the Anti-Graft Law against all the accused, asserting that the SB minutes had been falsified to grant authority to IBC for massive quarrying activities without proper permits.

During the trial, Partisala presented a copy of the SB minutes (Exhibit “8”) that differed from the prosecution’s version (Exhibit “B”). Partisala’s version indicated that Resolution Nos. 30-A and 30-B were deliberated and approved by the SB, while the prosecution’s version did not reflect this. The prosecution argued that Partisala’s version was falsified, containing insertions to make it appear that the resolutions had been enacted. Witnesses Trojillo and Albacete, who were SB members, testified that Resolution Nos. 30-A and 30-B were never deliberated on during the June 21, 1996 session.

The Sandiganbayan found Partisala guilty beyond reasonable doubt of both Falsification of Public Documents and violation of Section 3(e) of RA 3019. It gave credence to the prosecution’s version of the SB minutes (Exhibit “B”) and the testimonies of witnesses Trojillo and Albacete, who stated that the minutes were not signed by Partisala and contained items that were not discussed during the session. The Sandiganbayan concluded that Partisala had acted with evident bad faith in participating in the falsification of the resolutions, granting unwarranted benefits to IBC.

On appeal, Partisala argued that the prosecution failed to prove the falsification and that the prosecution should have presented the true or real copy of the minutes. However, the Supreme Court disagreed, emphasizing that all the elements of Falsification of Public Documents were duly established. Citing Constantino v. People, the court reiterated that the elements of Falsification of Public Documents are: (1) the offender is a public officer; (2) takes advantage of official position; (3) falsifies a document by causing it to appear that persons participated in any act or proceeding; and (4) such persons did not in fact so participate in the proceeding.

“Falsification of Public Document is committed when the public document is simulated ‘in a manner so as to give it the appearance of a true and genuine instrument, thus, leading others to errors as to its authenticity.’” (Constantino v. People, G.R. No. 225696, April 8, 2019, citing Goma v. Court of Appeals, 596 Phil. 1, 13 (2009))

In this case, the Supreme Court found that Partisala, as Vice Mayor, took advantage of his position to falsify the SB minutes, causing it to appear that Resolution Nos. 30-A and 30-B were deliberated upon when they were not. The testimonies of SB members Trojillo and Albacete supported this finding, affirming that the minutes presented by Partisala contained insertions that were not discussed during the session. The Supreme Court held that even without the prosecution presenting Malaga (the source of Exhibit “B”) to identify the minutes, the elements of Falsification of Public Document were duly established.

As to the violation of Section 3 (e) of R.A. No. 3019, the Anti-Graft and Corrupt Practices Act, the Supreme Court emphasized that Partisala acted with manifest partiality and bad faith by signing Exhibit “8” and persuading other sangguniang members to sign it, knowing that it contained items not discussed during the session. This action led to Mondejar, the mayor, being authorized to enter into a MOA with IBC, which was grossly disadvantageous to the government. The court cited Ampil v. Office of the Ombudsman to specify the elements of a violation under Section 3(e) of RA 3019:

(1) The offender is a public officer;
(2) The act was done in the discharge of the public officer’s official, administrative or judicial functions;
(3) The act was done through manifest partiality, evident bad faith, or gross inexcusable negligence; and
(4) The public officer caused any undue injury to any party, including the Government, or gave any unwarranted benefits, advantage or preference. (Ampil v. Office of the Ombudsman, 715 Phil. 733, 755 (2013))

By allowing IBC to extract sand and gravel without the necessary permits and without paying taxes, the SB of Maasin, Iloilo, acted without authority and caused undue injury to the government. The Supreme Court concluded that Partisala’s participation in falsifying the minutes was crucial in enabling the execution of the MOA and granting unwarranted benefits to IBC. The Supreme Court found that without the participation of Partisala, as the presiding officer of the SB, in enacting Resolution No. 30-A and Resolution No. 30-B, through falsification of the minutes of the regular session dated June 21, 1996, the said benefit, advantage, or preference would not have been probable.

FAQs

What was the key issue in this case?	The key issue was whether Arnaldo Partisala, as Vice Mayor of Maasin, Iloilo, was guilty of Falsification of Public Documents and violation of the Anti-Graft and Corrupt Practices Act by falsifying SB minutes to benefit a private corporation.
What is Falsification of Public Documents under Article 171 of the RPC?	Falsification of Public Documents involves a public officer taking advantage of their position to falsify a document in a way that it appears genuine, leading others to believe it is authentic. In this case, Partisala was found guilty of making it appear that the SB had approved resolutions when they had not.
What is Section 3(e) of RA 3019 (Anti-Graft and Corrupt Practices Act)?	Section 3(e) of RA 3019 prohibits public officers from causing undue injury to any party, including the government, or giving unwarranted benefits, advantage, or preference to another party through manifest partiality, evident bad faith, or gross inexcusable negligence. Here, Partisala was found to have given unwarranted benefits to IBC.
What evidence did the prosecution present to prove the falsification?	The prosecution presented a different version of the SB minutes (Exhibit “B”) and the testimonies of SB members Trojillo and Albacete, who testified that the resolutions in question were never deliberated upon during the session. This evidence contradicted Partisala’s version (Exhibit “8”).
Why was Partisala’s version of the SB minutes (Exhibit “8”) considered falsified?	The court found that Exhibit “8” contained insertions that were not discussed during the SB session on June 21, 1996. This was supported by the testimonies of witnesses Trojillo and Albacete, who testified that the minutes were altered.
What was the penalty imposed on Partisala for Falsification of Public Documents?	The Supreme Court modified the Sandiganbayan’s penalty to imprisonment of two (2) years of prision correccional, as minimum, to eight (8) years and one (1) day of prision mayor as maximum, and a fine of P5,000.00.
What was the penalty for violating Section 3(e) of RA 3019?	The Sandiganbayan meted the penalty of imprisonment of six (6) years and one (1) month, as minimum, to ten (10) years, as maximum; and perpetual disqualification from public office.
What is the significance of this ruling?	This ruling underscores the importance of maintaining the integrity of public documents and holding public officials accountable for abusing their positions for personal gain. It reinforces the judiciary’s commitment to upholding transparency and preventing corruption in local governance.

This case serves as a crucial reminder of the legal duties of public officials to act with integrity and transparency. The ruling highlights the severe consequences of falsifying public documents and engaging in corrupt practices that undermine public trust and cause undue injury to the government and its citizens. Strict adherence to these principles is essential for maintaining good governance and ensuring accountability in public service.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People vs. Partisala, G.R. Nos. 245931-32, April 25, 2022