FACTS:

In this case, Francisco M. Lecaroz and Lenlie Lecaroz were convicted by the Sandiganbayan of thirteen counts of estafa through falsification of public documents. Francisco Lecaroz was the Municipal Mayor of Santa Cruz, Marinduque while Lenlie Lecaroz was the outgoing chairman of the Kabataang Barangay (KB) of Barangay Bagong Silang and a member of its Sangguniang Bayan. In the 1985 election for Kabataang Barangay, Jowil Red won as KB Chairman of Barangay Matalaba. Lenlie Lecaroz did not run as a candidate in this election as he was no longer qualified after reaching the age limit. Red was appointed by then President Ferdinand Marcos as a member of the Sangguniang Bayan representing the KBs of Santa Cruz. Imee Marcos-Manotoc, the National Chairperson of the organization, sent a telegram to Red confirming his appointment. Mayor Lecaroz informed Red that he could not yet sit as a member of the municipal council until his appointment was cleared by the Governor of Marinduque. Red finally received his appointment papers in January 1986. However, he was still not allowed by the mayor to assume his position. Meanwhile, Mayor Lecaroz prepared and approved payroll payments for Lenlie Lecaroz covering a period of 26 quincenas. Lenlie Lecaroz signed the first payroll but authorized someone else to sign the succeeding payrolls and claim the corresponding salaries. Red filed criminal complaints against Mayor Lecaroz and Lenlie Lecaroz for refusing to let him assume the position of KB sectoral representative. The Ombudsman filed informtions for estafa through falsification of public documents against both petitioners. The Sandiganbayan found them guilty and sentenced them to imprisonment, fines, and perpetual special disqualification from public office.

The case involves accused Mayor Lecaroz and his son, Lenlie Lecaroz. It is alleged that Mayor Lecaroz committed falsification of public documents by making untruthful statements in a narration of facts. Lenlie Lecaroz, on the other hand, received salaries from the municipality for services he did not render, which constitutes Estafa. Conspiracy was alleged in the case and was found sufficiently substantiated by the evidence presented. Mayor Lecaroz reinstated his son in the municipal payrolls even though he was not entitled to it. It is concluded that there was conspiracy in the commission of Estafa between father and son. However, Mayor Lecaroz was acquitted of violating a specific provision of the law. The Sandiganbayan denied the motion for reconsideration filed by the accused, prompting them to elevate the case to the Supreme Court. Several issues are raised in the petition, including the validity of Red's assumption of office, Lenlie's entitlement to hold over, the elements of the crimes charged, and the conviction based on a different manner from that alleged in the information. The Sandiganbayan based its conviction on the premise that Jowil Red could not assume a seat in the Sanggunian without a valid appointment and that Lenlie Lecaroz could not hold over after his term expired. The laws on the terms of office of KB youth sectoral representatives and KB Federation Presidents are examined to resolve the issues.

Petitioner Lenlie Lecaroz was elected as a member of the Sangguniang Bayan (SB). However, respondent Nicasio Dimapilis filed a petition seeking to disqualify Lecaroz as a KB sectoral representative to the SB, claiming that Lecaroz did not present an authenticated copy of his appointment papers and did not take a valid oath of office. Despite his term expiring, Lecaroz continued to hold the position of SB member in a holdover capacity. The Sandiganbayan rejected Lecaroz's holdover claim, stating that the holdover provision only applies to positions in the KB and not in the SB. However, the Supreme Court disagreed, stating that the concept of holdover implies that the incumbent continues to hold the position until a successor is elected and qualified. Although the law did not explicitly state that a member of the SB can hold over, it also did not prohibit it. Therefore, Lecaroz was allowed to continue as a member of the SB in a holdover capacity.

ISSUES:

1. Validity of Jowil Red's Assumption of Office

   • Whether or not Jowil Red validly and effectively assumed the office of KB Federation President and the corresponding term of office of accused Lenlie Lecaroz expired.

2. Holdover Capacity

   • Whether or not Lenlie Lecaroz could continue to occupy the office in a holdover capacity despite the alleged expiration of his term.

3. Criminal Liability under Article 171

   • Whether or not the petitioners committed the crime of falsification of public documents under Article 171 of the Revised Penal Code and estafa.

4. Effects of Good Faith and Lack of Criminal Intent

   • Whether the petitioners acted in good faith and without criminal intent, thus exempting them from liability.

RULING:

1. Validity of Jowil Red's Assumption of Office

   • Ruling Jowil Red did not validly assume the office because the oath of office he took was not administered by an authorized official. Consequently, Lenlie Lecaroz continued as a member in a holdover capacity.

2. Holdover Capacity

   • Ruling The concept of holdover applies, allowing Lenlie Lecaroz to continue in office until his successor is duly qualified and appointed.

3. Criminal Liability under Article 171

   • Ruling The elements of falsification under Article 171, particularly the first and third elements, were not satisfied. The certification of payrolls by Mayor Francisco Lecaroz was a legal opinion, not a narration of false facts. Therefore, the petitioners did not commit falsification or estafa.

4. Effects of Good Faith and Lack of Criminal Intent

   • Ruling The petitioners acted in good faith and without criminal intent. There is no evidence of malicious intent or conspiracy. Any mistakes made were judgmental errors, not criminal acts.

PRINCIPLES:

1. Constitutional and Legislative Intent

   • Public officers continue to hold office until their successors are duly appointed and qualified, preventing any vacuum in public positions.

   • Absence of explicit legislative prohibition implies allowance for holdover positions.

2. Criminal Liability

   • For the crime of falsification, there must be a false narration of facts, legal obligation to disclose the truth, absolutely false facts, and intent to injure.

   • Good faith and the absence of criminal intent exempt from criminal liability.

3. Concept of Holdover

   • Holdover is implied when an officeholder remains in office after the expiration of their term due to absence of a qualified successor.

4. Burden of Proof in Conspiracy

   • Conspiracy must be established beyond reasonable doubt and cannot rely solely on familial relationships.