FACTS:

Petitioner Roberto Guillergan was indicted by the Office of the Ombudsman for estafa through falsification of public documents. Guillergan, a Lieutenant Colonel in the Armed Forces of the Philippines, directed the Chief Clerk of the Comptroller's Office to prepare payrolls for civilian intelligence agents. The payrolls were certified as correct by Guillergan and approved by Brigadier General Rio. Guillergan would direct another officer to affix his initials on the payrolls whenever they were returned for lack of signatures. The CIAs' payrolls in Region 6 were covered by cash advances payable to Captain Maclang, Jr. Guillergan would receive the cash or checks and turn them over to Rio. In addition, Rio received "administrative funds" which he requested to be re-aligned to "intelligence funds." The case against Rio was eventually dismissed after he died. Guillergan was eventually found guilty by the Sandiganbayan Second Division of falsification of public documents and sentenced to imprisonment. The other accused were acquitted for lack of proof of guilt beyond reasonable doubt. The issues in this case are whether the Sandiganbayan can convict Guillergan of a different offense from that charged in the Information, and whether Guillergan is guilty of falsification of public documents beyond reasonable doubt.

ISSUES:

1. Whether or not the Sandiganbayan can convict Guillergan of violation of Article 172 of the RPC under an Information that charged him with estafa in relation to Article 171 of the code;

2. Whether or not petitioner is guilty beyond reasonable doubt of the crime of falsification of public documents.

RULING:

1. The Sandiganbayan can convict Guillergan of violation of Article 172 of the RPC under an Information that charged him with estafa in relation to Article 171 of the code. The court ruled that the elements of the offense charged in the Information also include the essential elements of the offense for which Guillergan was convicted. The court considered the factual circumstances and evidence presented, and concluded that Guillergan's acts constitute falsification of public documents under Article 172 of the RPC.

2. Petitioner is guilty beyond reasonable doubt of the crime of falsification of public documents. The court found that Guillergan, as a Lieutenant Colonel in the AFP, directed the falsification of payrolls and other documents to facilitate the processing of payments to civilian intelligence agents. Guillergan's actions were proven through the testimonies of witnesses and other pieces of evidence. The court convicted him based on the elements of the crime of falsification of public documents and the evidence presented.

PRINCIPLES:

• The court can convict an accused of an offense other than that charged in the Information if the essential elements of the offense of which he was convicted are also elements of the offense charged in the Information.

• The guilt of an accused must be proven beyond reasonable doubt based on the elements of the crime charged and the evidence presented.