G.R. No. 82197 March 13, 1989
MANUEL L. SIQUIAN, petitioner, vs. THE PEOPLE OF THE PHILIPPINES and THE COURT OF APPEALS, respondents.

FACTS

Petitioner Manuel L. Siquian, the Municipal Mayor of Angadanan, Isabela, was charged with falsification of a public document under Article 171(4) of the Revised Penal Code. The information alleged that on July 1, 1975, he prepared and signed an official communication (CS Form No. 203) to the Civil Service Commissioner, certifying the availability of funds to support the appointment of Jesusa B. Carreon as a clerk. This certification was a legal requirement for the appointment. However, the prosecution established that no such funded position existed in the municipal plantilla for the fiscal year 1975-1976, as the municipal council had failed to enact a new budget, causing the previous year’s budget to be automatically re-enacted. That re-enacted budget contained no appropriation for the new clerk position to which Carreon was appointed.
The evidence showed that Mayor Siquian appointed Carreon, who then worked from July to December 1975 but remained unpaid because no funds were allocated for her salary. The appointment and the accompanying certification were processed. During trial, the petitioner, after initially participating, ceased to appear. His counsel eventually withdrew, citing loss of contact as the petitioner had gone abroad. Consequently, the trial court deemed him to have waived his right to present evidence and decided the case based solely on the prosecution’s evidence, finding him guilty.

ISSUE

Whether the petitioner is guilty beyond reasonable doubt of the crime of falsification of public document.

RULING

Yes, the Supreme Court affirmed the petitioner’s conviction. The legal logic centers on the elements of falsification under Article 171(4), which requires that a public officer made untruthful statements in a narration of facts in a public document. The certification of fund availability (CS Form No. 203) is a public document required by civil service rules. By signing it, Mayor Siquian asserted a fact—that funds were available for the position—which he knew to be false, as no such item existed in the re-enacted budget. His knowledge of the falsity is inferred from his position as mayor, who would be aware of the municipal budget and plantilla. The act caused damage, as it led to Carreon’s appointment and subsequent unpaid services, and it perverted the official function of the certification process.
The Court rejected the petitioner’s claim of denial of due process. His failure to appear at trial and his counsel’s withdrawal, after the court denied his motions for change of venue, constituted a waiver of his right to be present and to present evidence. The trial court correctly proceeded to judgment based on the prosecution’s evidence, which was sufficient to establish guilt beyond reasonable doubt. The separate concurring opinion noted that while officials often rely on subordinates for routine certifications, the evidence here showed the petitioner’s personal awareness of the non-existent position, distinguishing it from mere negligence.