FACTS:

The case involves petitioner Romeo D. Lonzanida, who was the Municipal Mayor of San Antonio, Zambales. He was charged with ten counts of Falsification of Public Document under the Revised Penal Code before the Office of the Provincial Prosecutor. The complaints alleged that petitioner notarized thirteen Affidavits of Ownership of public land, which were executed by individuals who either denied signing them or were minor children of petitioner and his assistant. The complaints also alleged that petitioner notarized thirteen Joint Affidavits of two disinterested persons, one of whom was illiterate and the other already deceased.

During the trial, witnesses were presented, including the Municipal Assessor and the complainants. Petitioner pleaded "not guilty" to all charges.

The Sandiganbayan convicted the petitioner of falsification and denied his motion for reconsideration. The petitioner then filed a manifestation and submission of evidence, consisting of affidavits of recantation from some of the witnesses. The Sandiganbayan deferred ruling on this and required the witnesses to appear and testify before the court.

The prosecution presented witnesses, including Elsie de Dios and Leopoldo Cacho, who later recanted their previous testimonies. They claimed that they were compelled by petitioner's political enemies to testify against him and sign documents they did not understand. Another witness, Rene Abad, also testified that he was used by petitioner's political adversaries and was made to sign a prepared affidavit without fully comprehending its contents. Based on these testimonies, the Sandiganbayan granted petitioner a new trial and allowed him to present additional evidence. However, in the subsequent decision, the Sandiganbayan belittled the recantation of the witnesses and convicted petitioner of the crimes charged.

ISSUES:

1. Whether the Sandiganbayan committed any reversible error in convicting the petitioner of falsification of public documents.

2. Whether there was sufficient evidence to prove the guilt of the petitioner beyond reasonable doubt.

3. Whether the factual findings of the Sandiganbayan are conclusive upon the Supreme Court

4. Whether the elements of falsification of a public document were proven in this case

5. Whether the petitioner participated in the preparation and execution of the Affidavits of Ownership and Mayor's Certification.

6. Whether the prosecution's failure to present the original Mayor's Certification is fatal to the case.

7. Whether the petitioner can be considered the material author of the falsifications.

8. Whether the subject lot remaining public and the absence of damage resulting from the issuance of the tax declaration are valid defenses.

9. Whether the circumstantial evidence presented by the prosecution is sufficient to warrant the petitioner's conviction.

RULING:

1. The Supreme Court initially denied the petitioner's petition for review on certiorari, but later reinstated and gave due course to the petition upon motion for reconsideration. The Court resolved to take a second look at the case and the facts and circumstances involved.

2. The factual findings of the Sandiganbayan are conclusive upon the Supreme Court, unless certain exceptions are present such as when the conclusion is based on speculation, there is an error in the inference made, there is grave abuse of discretion, there is a misapprehension of facts, or when the findings are contradicted by evidence on record. In this case, none of these exceptions were present, thus the conclusion made by the Sandiganbayan on the sufficiency of the evidence of the prosecution stands.

3. The elements of falsification of a public document were proven in this case. The accused petitioner is a public officer who took advantage of his position to falsify documents by signing oaths under false circumstances. The accused petitioner's acts of signing the oaths were clearly an abuse of the powers of his office, and the elements of the crime were proven during the trial.

4. The court found that the petitioner participated in the preparation and execution of the Affidavits of Ownership and Mayor's Certification based on the similarities of his signatures and the fact that he issued the Mayor's Certification attesting to the false facts contained in the affidavits.

5. The court stated that the Mayor's Certification was not the subject of the criminal cases against the petitioner and that the submission of a certified xerox copy of the document was sufficient.

6. The court held that the petitioner is the material author of the falsifications based on his acts of administering the oath to the alleged affiants and issuing the Mayor's Certification which displayed his intention to falsify the documents for his benefit.

7. The court recognized that the intent to gain or injure a third person is not necessary to establish the crime of falsification of public or official documents. Furthermore, the court emphasized that the petitioner successfully obtained the tax declaration using the falsified documents, regardless of whether the subject lot remains public or if there was no resulting damage.

8. The court held that the circumstantial evidence presented by the prosecution is sufficient to warrant the petitioner's conviction. The requisites for circumstantial evidence to sustain a conviction were met, namely: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. The court found no reason to disagree with the Sandiganbayan's judgment of conviction and affirmed their decision.

PRINCIPLES:

• Reversibility of errors committed by the Sandiganbayan - The Supreme Court exercises its discretionary appellate jurisdiction when the Sandiganbayan commits reversible errors that warrant a review of the case.

• Burden of proof beyond reasonable doubt - To secure a conviction, the prosecution must prove the guilt of the accused beyond reasonable doubt.

• The factual findings of the Sandiganbayan are generally conclusive upon the Supreme Court, except when certain exceptions are present.

• In the falsification of public or official documents, the presence of the idea of gain or intent to injure a third person is not necessary. What is punished is the violation of public faith and the destruction of the truth proclaimed in the document.

• There is no need for direct proof that the accused was the author of the forgery, as long as there is sufficient evidence to show that the accused took part in the falsification.

• A person can be considered the material author of the falsification of documents if they participated in their preparation and execution, even if their signature is absent from some of the documents.

• The failure to present the original document in court does not automatically render the evidence inadmissible, especially if a certified xerox copy is available.

• In the crime of falsification of public or official documents, the presence of gain or intent to injure a third person is not necessary to establish the offense.

• The successful acquisition of benefits or advantages using falsified documents is sufficient to establish the guilt of the person responsible for the falsification.

• Circumstantial evidence may be resorted to when insisting on direct testimony would ultimately lead to setting felons free.

• The standard followed by the courts in appreciating circumstantial evidence requires that all circumstances proved must be consistent with each other, consistent with the hypothesis that the accused is guilty, and inconsistent with the hypothesis of innocence or any other rational hypothesis except guilt.

• The evidence presented, even if circumstantial, should constitute an unbroken chain leading to one fair and reasonable conclusion, pointing to the accused as the guilty person.

• The evidence should leave no room for reasonable doubt as to the guilt of the accused.

• If inculpatory facts and circumstances are capable of two or more explanations, one consistent with innocence and the other with guilt, the evidence does not fulfill the test of moral certainty, and thus, is not sufficient to convict the accused.