G.R. No. L-56132 October 2, 1986
VICENTE LUZ, petitioner, vs. THE HONORABLE SANDIGANBAYAN and THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Nestor R. Rueda, the former Municipal Treasurer of Bula, Camarines Sur, filed a complaint with the Sandiganbayan charging several individuals, including petitioner Vicente Luz (his successor as Acting Municipal Treasurer), with malversation of public funds and falsification of public documents. The charges stemmed from a scheme wherein seven unpaid municipal policemen were included in a payroll for laborers working on municipal roads and bridges. Municipal Mayor Sabino Pontanal issued a certification to this effect. Petitioner Luz, in his capacity as disbursing officer, subsequently signed the corresponding voucher (Voucher No. 118), leading to the payment of P48.00 to each of the seven policemen, totaling P336.00.
After trial, the Sandiganbayan acquitted all accused, including Luz, of malversation. All accused except Luz were also acquitted of falsification. Luz alone was convicted of falsification of a public document. The court sentenced him to an indeterminate prison term and a fine. Luz filed a motion for reconsideration, which was denied, prompting this petition for review before the Supreme Court.

ISSUE

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

RULING

The Supreme Court acquitted petitioner Vicente Luz on the ground of reasonable doubt. The Court emphasized that the prosecution failed to present proof that Luz had knowledge of Mayor Pontanal’s scheme to enable the policemen to receive payment through the irregular payroll. Luz’s defense was that he did not know the payees were policemen and that his duty in processing the voucher was purely ministerial upon seeing the mayor’s certification.
The legal logic centers on the nature of Luz’s official duty and the requisite criminal intent for falsification. The Court ruled that, in the absence of evidence proving his complicity in the fraudulent scheme, Luz was merely performing a ministerial function. As a disbursing officer, his obligation was to verify the presence of the required certification from the mayor, not to conduct an independent investigation into the actual performance of labor by the individuals listed. Citing People v. Reodica, the Court affirmed that such verification duty does not extend to physically confirming whether municipal employees or laborers are actually at work, as this would impose an impossible burden on disbursing officers. Consequently, lacking proof of malicious intent or conspiracy, the presumption of good faith in the performance of official duty stands, and his conviction cannot be sustained.