8. Venancio M. Sevilla vs. People of the Philippines

8. Venancio M. Sevilla vs. People of the Philippines Facts: Venancio Sevilla, a newly elected councillor of Malabon City, was charged with the crime of Falsification of Public Document when he allegedly stated in his Personnel Data Sheet, an official document, that he had no pending criminal case when in fact he is accused in a criminal case for Assault Upon an Agent of A Person In Authority. Thereby peverting the truth. In his defense, he alleged that he merely signed the prepared PDS which he ordered copied from his old PDS. This prepared PDS was brought to his home by his secretary as he still had no office then. After trial, the Sandiganbayan found him liable for the crime of Falsification of Public document thru Reckless Imprudence. In his appeal to the Supreme Court, Venancio theorises that he cannot be held liable for Falsification of Public Document thru Reckless Imprudence because the Information charged him with Intentional Falsification of Public Document. Issue: Whether or not Sevilla can be held liable for the crime of Falsification of Public Document thru Recklesss Imprudence. Held:

The appeal is dismissed for lack of merit. At the outset, it bears stressing that the Sandiganbayan’s designation of the felony supposedly committed by Sevilla is inaccurate. The Sandiganbayan convicted Sevilla of reckless imprudence, punished under Article 365 of the RPC, which resulted into the falsification of a public document. However, the Sandiganbayan designated the felony committed as "falsification of public document through reckless imprudence." The foregoing designation implies that reckless imprudence is not a crime in itself but simply a modality of committing it. Quasi-offenses under Article 365 of the RPC are distinct and separate crimes and not a mere modality in the commission of a crime. Sevilla’s claim that his constitutional right to be informed of the nature and cause of the accusation against him was violated when the Sandiganbayan convicted him of reckless imprudence resulting to falsification of public documents, when the Information only charged the intentional felony of falsification of public documents, is untenable. To stress, reckless imprudence resulting to falsification of public documents is an offense that is necessarily included in the willful act of falsification of public documents, the latter being the greater offense. As such, he can be convicted of reckless imprudence resulting to falsification of public documents notwithstanding that the Information only charged the willful act of falsification of public documents.