G.R. No. 164166 & 164173-80; October 17, 2007
RODOLFO S. DE JESUS, Petitioner, vs. HON. SANDIGANBAYAN and OFFICE OF THE OMBUDSMAN, Respondents.

FACTS

Petitioner Rodolfo S. De Jesus, Deputy Administrator of the Local Water Utilities Administration (LWUA), and a co-accused were charged before the Sandiganbayan with nine counts of falsification of public documents under Article 171(4) of the Revised Penal Code. The informations alleged that they conspired to falsify appointment papers of confidential staff by antedating them to October 15, 2001, thereby enabling the appointees to receive salaries and allowances for the period from that date to December 31, 2001, when their official appointments were only approved on December 12, 2001. The accused filed a motion to quash, arguing that the Sandiganbayan lacked jurisdiction because the alleged acts were not committed in relation to their office, and that the facts charged did not constitute the offense of falsification.
The Sandiganbayan denied the motion to quash, ruling that the preparation and issuance of appointment papers were inherent in the functions of the petitioner as Deputy Administrator and his co-accused as Human Resource Management Department Manager. It held that the allegations in the informations sufficiently established that the offense was committed in relation to their office, thus falling within the court’s jurisdiction. Petitioner’s motion for reconsideration was likewise denied.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in denying the motion to quash the informations for falsification.

RULING

The Supreme Court dismissed the petition and affirmed the Sandiganbayan’s resolutions. The Court held that the Sandiganbayan did not commit grave abuse of discretion, as its denial of the motion to quash was based on a correct interpretation of the law and the allegations in the informations.
On jurisdiction, the Court ruled that the allegations in the informations were sufficient to establish that the offense was committed in relation to the petitioner’s office. The informations explicitly stated that the accused, while in the performance of their official functions and taking advantage of their official positions, falsified the appointment documents. The law does not require the information to detail the specific duties of the accused; it is enough that it alleges the intimate connection between the offense and the discharge of official duties. The petitioner’s argument that he had no appointing authority was a matter of defense best ventilated during trial, not a ground for a motion to quash based on the information’s sufficiency.
Regarding the sufficiency of the facts to constitute the offense, the Court found that the informations adequately alleged all the elements of falsification by a public officer under Article 171(4): that the accused is a public officer; that he took advantage of his official position; and that he committed any of the acts of falsification, in this case, making untruthful statements in a narration of facts. The allegation that they antedated the appointments, making it appear the appointees assumed office earlier than they actually did, constitutes an untruthful statement in a narration of facts. The petitioner’s obligation to disclose the truth arose from his official duty to prepare correct appointment papers. The Court concluded that no grave abuse of discretion attended the Sandiganbayan’s rulings.