TL;DR

The Supreme Court affirmed the Sandiganbayan’s decision to proceed with the trial against Mayor Oscar de los Reyes for falsification of a public document. The Court underscored the importance of official minutes as a reliable record of legislative proceedings. The ruling emphasizes that local chief executives cannot claim ignorance of the contents of resolutions they approve, especially when the minutes show that the resolution was not properly discussed or approved by the Sangguniang Bayan. This decision reinforces the principle that public officials are accountable for the veracity of official documents and cannot use legislative processes to shield themselves from scrutiny. The case highlights the reliance placed on minutes as evidence of official actions and underscores the duty of public officials to ensure the accuracy of public records.

Minutes Matter: When a Mayor’s Signature Faces Scrutiny

This case revolves around Mayor Oscar de los Reyes’s alleged falsification of Resolution No. 57-S-92, which appropriated funds for employee terminal leave. The central question is whether the minutes of the Sangguniang Bayan (SB) session, which did not reflect the resolution’s approval, can serve as evidence against the Mayor. The prosecution argued that Mayor de los Reyes, in collusion with an SB member, falsely made it appear that the resolution had been duly approved. The Mayor, on the other hand, contended that the resolution’s approval was a legislative act, and as chief executive, he merely performed a ministerial function by signing it.

The Supreme Court disagreed with the Mayor’s argument, emphasizing that his role in approving resolutions is not merely ministerial. Article 109(b) of the Local Government Code grants the local chief executive the power to veto ordinances or resolutions, indicating a discretionary function that requires careful consideration. This veto power implies that the Mayor must apply judgment and intelligence when deciding whether to approve or reject a resolution. Therefore, the Mayor’s signature carries significant weight, and he cannot claim ignorance of the resolution’s contents. This contrasts with a purely ministerial duty, where no discretion is involved, such as recording a document.

The Court also placed significant weight on the minutes of the Sangguniang Bayan session. These minutes serve as the official record of what transpired during the legislative proceedings. In numerous cases, the Supreme Court has relied on minutes to resolve conflicting claims and ascertain the truth of the proceedings. The absence of any mention of Resolution No. 57-S-92 in the minutes was a crucial factor in the Court’s decision. The Court stated that it gives “full recognition to the minutes as the official repository of what actually transpires in every proceeding.” This reliance on documented evidence aligns with principles of transparency and accountability in governance.

The Mayor argued that other SB members had submitted a joint affidavit attesting to the resolution’s approval, but the Court dismissed this as a belated attempt to bolster his position. The timing of the affidavit suggested it was a last-minute effort to counter the evidence presented by the prosecution. The Court underscored that the Sandiganbayan correctly relied on the official minutes, which are created contemporaneously with the proceedings. This approach contrasts with relying on later recollections, which may be influenced by personal biases or fading memories.

The Supreme Court referenced several previous cases to illustrate the importance of minutes in legal proceedings. In Malinao v. Reyes, the minutes revealed that the Sanggunian only took a vote on the administrative case but did not render a decision. In Pimentel v. Garchitorena, the case involved falsification of excerpts from the minutes of Sangguniang Panlalawigan sessions. These cases demonstrate the Court’s consistent reliance on minutes as a factual record of legislative and administrative actions. In this context, the Court highlighted that the arguments raised by the petitioner were more appropriate for the trial on the merits, where the evidence could be thoroughly examined and weighed.

The Court’s decision underscores the importance of maintaining accurate and complete records of legislative proceedings. These records serve as a vital check on the actions of public officials and ensure accountability in governance. By prioritizing official minutes as reliable evidence, the Court has set a high standard for transparency and integrity in local government. The Sandiganbayan was directed to proceed with the arraignment and trial, allowing for a full examination of the evidence and arguments presented by both sides.

FAQs

This case serves as a reminder of the importance of transparency and accountability in local governance. Accurate record-keeping and adherence to proper procedures are essential for maintaining public trust and ensuring the integrity of government actions. The case also highlights the potential consequences for public officials who fail to uphold these standards.

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: De Los Reyes v. Sandiganbayan, G.R. No. 121215, November 13, 1997