Manzanaris v. People of the Philippines
REITERATIONFacts
The Antecedents: Petitioner Selso M. Manzanaris, as Clerk of Court of the Court of First Instance of Basilan, was the custodian of all court records. Among these was Original Certificate of Title No. 877, which was part of the property bond posted by Geronimo Borja in Criminal Case No. 299. Upon discovering that the original title was missing from the Register of Deeds, Manzanaris ordered a subordinate to deliver the owner's copy of OCT No. 877 to Geronimo Borja for the purpose of administrative reconstitution. Borja signed a receipt stating the title was to be reconstituted and returned to the court. This release was done without a written order from the presiding judge. Procedural History: Although Mrs. Trinidad M. Borja, wife of Geronimo Borja, succeeded in reconstituting the title in November 1974, it was not returned to the court. In June 1975, the building housing the court and its records burned down. In 1981, Atty. Filoteo Jo filed a motion to borrow OCT No. 877, but the motion was denied based on petitioner's certification that the title was destroyed in the fire. Atty. Jo later informed petitioner that Trinidad Borja had obtained possession of the title and had it reconstituted. Petitioner then admitted delivering the title to Geronimo Borja for reconstitution and repeatedly asked Mrs. Borja to return it, but she could not locate it. The Petition: Petitioner was found guilty by the Sandiganbayan of infidelity in the custody of documents under Article 226, paragraph 2 of the Revised Penal Code. He was sentenced to an indeterminate penalty, a fine, subsidiary imprisonment, and temporary special disqualification. The Sandiganbayan rejected his defense of good faith. Petitioner sought review of this decision.
Issue(s)
Whether the Sandiganbayan erred in finding petitioner guilty of infidelity in the custody of documents under Article 226, paragraph 2 of the Revised Penal Code, considering the element of criminal intent. Whether the act of removing and delivering Original Certificate of Title No. 877 to Geronimo Borja for administrative reconstitution, without a written court order, constitutes infidelity in the custody of documents when done without criminal intent, specifically focusing on the petitioner's motive and the absence of illicit purpose.
Ruling
The Supreme Court reversed the decision of the Sandiganbayan, setting aside the conviction and acquitting the petitioner of the crime charged. Costs were ordered de oficio.
Ratio Decidendi
On the issue of whether petitioner is guilty of infidelity in the custody of documents: The Supreme Court held that to warrant a finding of guilt for the crime of infidelity in the custody of documents, the act of removal must be coupled with criminal intent or an illicit purpose. The Court invoked the principle "Actus non facit, nisi mens sit rea," emphasizing that a crime requires a guilty mind. In this case, the petitioner's act of removing the certificate of title from the court's files and delivering it to Geronimo Borja for administrative reconstitution was not prompted by criminal intent or an illegal purpose. On the issue of whether the act constitutes infidelity in the custody of documents without criminal intent: The Court found that he was motivated by a sincere desire to protect the interest of the Government, as the unreconstituted certificate of title was inefficacious as a property bond. The prosecution did not impute bad faith, nor was there anything in the record to suggest that the petitioner profited from the act. The Court reiterated the ruling in Kataniag vs. People, which states that if the removal of an official document is for an illicit purpose, the crime is committed, but if it is actuated by lawful or commendable motives, there would be no crime committed. Therefore, the act of removal, destruction, or concealment of public documents is punished only when it constitutes infidelity in the custody thereof. Since the petitioner's motive was to protect the State's interest and not to commit any illicit act, his actions did not constitute the crime charged.
Main Doctrine
To warrant a finding of guilt for the crime of infidelity in the custody of documents under Article 226 of the Revised Penal Code, the act of removal must be coupled with criminal intent or an illicit purpose. If the act is motivated by lawful or commendable motives, no crime is committed.