G.R. No. 76490 & 76558. October 6, 1995.
ISAGANI SABINIANO and RODOLFO MARTINEZ, petitioners, vs. THE HON. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioners Isagani Sabiniano and Rodolfo Martinez, along with other Bureau of Lands officials, were charged with Malversation of Public Funds through Falsification of Public Document. The information alleged that in July 1968, they conspired to falsify two traveling expense vouchers totaling P9,775.00 in favor of a certain Eutiquio Hedrosello for purported surveillance work. The vouchers bore the forged signatures of approving officers. A corresponding treasury warrant was prepared, signed by Sabiniano as Chief of the Budget and Fiscal Division, and encashed. Rodolfo Martinez, a casual employee, facilitated the encashment with the help of the cashier, Pedro Velasco.
The trial court convicted all accused of the complex crime of Estafa through Falsification of a Public Document, a ruling affirmed by the Court of Appeals. The court found conspiracy, noting the hurried processing of irregular vouchers and the cooperation in encashing the warrant. It held the crime was estafa, not malversation, as the misappropriated funds were not under the official accountability of all the accused.

ISSUE

The primary issue is whether the petitioners are guilty beyond reasonable doubt of the crime for which they were convicted.

RULING

The Supreme Court rendered separate rulings for each petitioner. For Isagani Sabiniano, the Court acquitted him. Applying the doctrine of qualified reliance from Arias v. Sandiganbayan, officials like Sabiniano, who sign documents in the regular course of duties, are not required to exhaust all means to verify their authenticity absent clear signs of forgery. Sabiniano, as Chief of the Budget and Fiscal Division, relied on the signatures of subordinate preparers and the initial approval by the Chief Accountant. There was no evidence he participated in the falsification or conspiracy.
For Rodolfo Martinez, the Court affirmed his conviction. As the one who presented the warrant for encashment and endorsed it, his possession and use of the forged treasury warrant created a presumption that he was the forger. His uncorroborated claim that he merely turned the money over to another official was insufficient to overcome this presumption. The Court upheld the conviction for Estafa through Falsification of a Public Document, ruling it is a lesser and cognate offense to the charged crime of Malversation through Falsification, and thus included therein. The penalty imposed was within the statutory range.