Luz v. Sandiganbayan
REITERATIONFacts
The Antecedents: Nestor R. Rueda filed a complaint with the Sandiganbayan charging Vicente Luz, the acting municipal treasurer and disbursing officer, along with the municipal mayor and other individuals, with malversation of public funds and falsification of public documents. The complaint alleged that the mayor included seven policemen, who were unable to get paid for their services, in the payroll for laborers on municipal roads and bridges. The mayor issued a certification to this effect, which was then signed by petitioner Luz as acting municipal treasurer. Consequently, the policemen were paid, resulting in the disbursement of P336.00 from government funds. Procedural History: After trial, all accused were acquitted of malversation of public funds. All accused except petitioner Vicente Luz were acquitted of falsification of public document. The municipal mayor died during the trial. Petitioner Vicente Luz was convicted of falsification of public document and sentenced to an indeterminate imprisonment ranging from two (2) years, four (4) months and one (1) day of prision correccional as minimum to eight (8) years and one (1) day of prision mayor as maximum, a fine of P2,000.00, and to pay the costs. His motion for reconsideration was denied. The Petition: Petitioner filed the instant petition, alleging that he had no knowledge of the mayor's scheme, did not know the policemen personally, and that his duty to allow payment was purely ministerial as long as the required certification from the municipal mayor was present. He argued that no law required him to verify the actual performance of duties by laborers.
Issue(s)
Whether petitioner Vicente Luz is guilty of falsification of public document. Whether petitioner's act of signing the voucher was a ministerial duty.
Ruling
The Supreme Court acquitted petitioner Vicente Luz on the basis of reasonable doubt. The Court held that no proof was presented to show that he knew of the mayor's plan. Furthermore, his actions were considered purely ministerial in view of the certification made by the municipal mayor, and there is no law or regulation requiring him to personally verify the performance of duties of municipal laborers.
Ratio Decidendi
On the issue of guilt for falsification of public document: The Court found that petitioner Vicente Luz should be acquitted on the ground of reasonable doubt. The prosecution failed to present sufficient proof that petitioner had knowledge of the scheme devised by the municipal mayor to include the policemen in the payroll for laborers. The Court emphasized that the presumption of good faith in favor of public officers should be considered. On the issue of whether petitioner's act of signing the voucher was a ministerial duty: Petitioner's act of signing the voucher was deemed purely ministerial because it was based on the certification issued by the municipal mayor. There is no legal requirement for a disbursing officer to personally investigate or verify whether laborers listed in a payroll are actually performing their assigned tasks, especially when a certification from the proper official, in this case, the municipal mayor, is provided. To impose such a duty would render the function of a disbursing officer practically impossible, as it would require him to go out and personally ascertain the performance of every employee or laborer. The Court cited precedents, such as People v. Reodica and U.S. v. Balais, to support the principle that duties based on certifications from superior officials are considered ministerial. Therefore, without proof of conspiracy or knowledge of the fraudulent scheme, and given the ministerial nature of his duty, petitioner cannot be held liable for falsification.
Main Doctrine
An acting municipal treasurer and disbursing officer who signs a voucher based on a certification from the municipal mayor, without knowledge of any scheme to defraud the government, should be acquitted on reasonable doubt, as his duty in such instance is considered purely ministerial.