Table of Contents

Ruzol vs Sandiganbayan G.R. No. 186739 ............................................................................................. 2

Unionbank vs People G.R No. 192565 .................................................................................................... 3
Choa vs People G.R. No. 142011 .............................................................................................................. 4
Batulanon vs People G.R No. 139857 ...................................................................................................... 5
Dabu vs Kapunan A.M No. RTJ-00-1600 ............................................................................................. 6

Submitted by: Baligad, Jovanni B. 2019-0243

Ruzol vs Sandiganbayan
G.R. No. 186739

Facts: Ruzol, a mayor of General Nakar, Quezon, organizes a multi-sectoral consultative assembly
composed of civil society groups, public officials and concerned stakeholders for the purpose of
regulating and monitoring the transportation of salvaged forest products in General Nakar. During
the assembly, the participants agreed that to regulate the salvaged goods, Ruzol shall issue a permit
to transport after payment of required fees to the municipal treasurer. On a span of 3 years, 221
permits were issued to various recipients, 43 of those came from Ruzol and the rest were signed
by his municipal administrator. Due to this, 221 criminal informations were filed against Ruzol
and his administrator with the Sandiganbayan, the latter found ruzol guilty of usurpation of
authority. Sandiganbayan ruled that only DENR has the authority to issue transport permits.
Ruzol’s issuance of such constitutes usurpation of official function of DENR.
Issue: w/n Ruzol’s issuance of Transport Permits is valid
Held: Yes. Under the Local Govt Code, the LGU also has the ample authority to promulgate rules,
regulations, and ordinance to monitor and regulate salvaged forest products, provided that the law
is being complied with. DENR is not the only govt instrumentality with such authority. Also, in
cases under usurpation of official functions, good faith is a defense. “Good faith” is the state of
mind denoting “honesty to intention and freedom from knowledge and circumstances which ought
to put the holder upon inquiry; an honest intention to abstain from taking any unconscious
advantage of another; even though technicalities of law; together with the absence of all
information, notice, or benefit, or belief of facts which render transaction unconscientious.” In this
case, the prosecution failed to prove the existence of ruzol’s criminal intent when he issued those
transport permits; it is also clear that ruzol only intended to regulate and monitor salvaged forest
products in General Nakar to avert illegal logging activities therein.

2
Unionbank vs People
G.R No. 192565

Facts: Tomas was charged in RTC for perjury for making a false narration in a certificate against
forum shopping. The accusation stemmed from unionbank’s 2 complaints, filed in two different
courts, for sum of money with prayer for a writ of replevin against sps. Tamondong and a John
Doe. The second complaint with an attached certificate of non-forum shopping was subscribed
and notarized in Makati. Both complaints showed that tomas executed and signed the certification
against forum shopping. Due to this, she was charged of perjury under art. 183 of the RPC with
Makati MeTC. Tomas filed a motion to quash the complaint upon the ground of improper venue,
but the lower court denied the motion. Tomas appealed the MeTC’s decision before the Makati
RTC, but the same also denied the appeal.
Issue: w/n Makati MeTC is not the proper venue for the perjury case of the petitioner
Held: No. Makati court has the rightful jurisdiction to hear the case. Venue is an important element
of jurisdiction in criminal cases, it is because 1. The jurisdiction of the trial court is limited to well-
defined territories such that a trial court can hear cases involving crimes committed in its territorial
jurisdiction, and 2. Laying the venue in criminal cases is grounded on the necessity and justice of
having the accused In the municipality of province where witnesses for his defense are available.
The venue of criminal cases is not only the place where the offense was committed, but also where
any of its essential elements took place. In this case, the elements of perjury are: 1. That the accused
made a statement under oath or executed an affidavit upon a material matter; b. that the statement
or affidavit was made before a competent officer, authorized to receive and administer oath; c. that
in the statement or affidavit, the accused made a willful and deliberate assertion of falsehood; d.
that the sworn statement of affidavit containing the falsity is required by law or made for a legal
purpose. In this case, Tomas committed all of these when she perfected her affidavit of certificate
of non-forum shopping in Makati and notarized the same therein. Hence, the crime of perjury,
together with its elements, were committed in Makati.

3
Choa vs People
G.R. No. 142011

Facts: Alfonso Choa, a Chinese national, filed with Bacolod RTC a petition for naturalization.
Alfonso testified on direct examination, but he was not able to finish the same. He then filed a
motion to withdraw his petition for naturalization. RTC granted the petition. Meanwhile, Leni,
wife of alfonso, filed a case of perjury against his husband for falsely; saying that she and their 2
children were residing in the stated address in alfonso’s petition for naturalization, and that he left
the said residence stated therein, and the accused was having an illicit affair with one stella saludar
and the two were living together with Bacolod MTCC, MTCC convicted alfonso of perjury.
Alfonso appealed to the RTC but the RTC denied the appeal, same with CA.
Issue: w/n alfonso may be tried of perjury despite of his withdrawal
Held: Yes. It is not necessary that the proceeding in which the perjury is alleged to have been
committed be first terminated before a prosecution for the said crime is committed. In this case,
the court cannot agree that alfonso cannot be prosecuted for perjury because the said document
that the perjury was committed was withdrawn. The crime has been consummated at the time he
filed his petition for naturalization and all the elements of perjury were also committed thereat.

4
Batulanon vs People
G.R No. 139857

Facts: complainant PCCI employed Batulanon as its cashier/manager for almost 2 years. She was
in charged of receiving deposits from and releasing loans to the member of the cooperative. During
an audit, certain irregularities concerning the release of loans were discovered. Consequently, 4
informations of estafa thru falsification of commercial documents were filed against batulanon.
Batulanon denied all the charges against her. The trial court convicted batulanon guilty of the
charges against her. The case was appealed before the CA but the CA affirmed the RTC ruling.
Batulanon, before the SC, argues that falsification of private document requires as an element
prejudice to a third person. She insists that PCCI has not been prejudiced by these loan transactions
because these loans are accounts receivable by the cooperative.
Issue: w/n batulanon can be convicted of falsification of private document even though the
information charged was estafa.
Held: Yes. Although the offense charged in the information is estafa through falsification of
commercial document, the accused could be convicted of falsification of private document under
the well-settled rule that it is the allegations in the information that determined the nature of the
offense and not the technical name given in the information. In this case, the acts of batulanon
and the information charged against him constitutes elements of falsification of private documents
under art. 172, par. 2 of the RPC, these are: 1. That the offender committed any of the acts of
falsification, except those in par. 7. Art 171; 2. That the falsification was committed in any private
document; and 3. That the falsification caused damage to a third party or at least the falsification
was committed with intent to cause such damage.

5
Dabu vs Kapunan
A.M No. RTJ-00-1600

Facts: Dabu was appointed assistant provincial prosecutor for Pampanga. She was transferred and
reassigned to Pampanga to serve 3 batches of RTC therein, namely Branches 50, 51, and 52. just
a few months into her assignment, she noticed that unlike in Branch 50, she was not being called
upon to intervene or investigate cases involving annulment in Br. 51 and 52 which are both
presided by Judge Kapunan. Upon hearing that there were some anomalies in the said court
regarding said cases, Dabu went to the office of the clerk of court and investigate the said court’s
records. She then found out that the records were being falsified and made to appear that a
prosecutor appeared during the hearings of annulment cases. Consequently, Atty. Jurado published
an article in Manila Standard about Dabu’s findings. Once the issue reached the SC, then CJ
Davide instructed Judge Gonzales of RTC Guagua Pampanga to submit inventories of marriage
annulment cases filed in RTC Br. 51 and 52 of Guagua Pampanga. The findings were reported to
Investigating Justice De Los Santos and it revealed the anomalies in the said RTC branches.
Kapunan denied the accusations and argued that his signatures on said records were forged, and
that he was also a victim of falsification and did not conspire or connive with other respondents.
During the pendency of the case, Kapunan died and his heirs continued to represent him. They
averred that the evidence of Dabu was insufficient and moved to dismiss the case.
Issue: w/n Kapunan is guilty of falsification of court records
Held: Yes. The SC ruled that Kapunan’s signatures were not forged. Kapunan failed to specifically
deny under oath his participation in the anomalous cases or to challenge the genuineness pg jos
signature appearing in the subject anomalous court records. Following the rules of court, this
amounts to an admission that he indeed signed the questioned records. In cases of falsification, the
rule is that, he who disavows the authenticity of his signature on a public document bears the
responsibility of presenting evidence to the effect and a mere disclaimer is not sufficient; as a rule,
forgery cannot be presumed and must be proved by clear, positive, and convincing evidence and
the burden of proof lies on the party alleging forgery. In this case, Kapunan failed to successfully
defend his allegation that his signature was forged.

6
7