Sandiganbayan junks perjury case vs former special prosecutor
The Sandiganbayan has dismissed the criminal cases against former Special Prosecutor Dennis Villa-Ignacio for allegedly failing to disclose that he faced administrative cases when he was applying for the position of Ombudsman in 2005.
In a nine-page resolution dated Aug. 2, the court’s First Division granted Villa-Ignacio’s motion to dismiss the criminal charges of falsification and perjury, citing the dismissal of the related administrative complaint for dishonesty and conduct prejudicial to the best interest of the service.
The Court of Appeals on Feb. 10, 2015 found the dishonesty case to be wanting in substantial evidence, a decision affirmed by the Supreme Court on May 1 this year. Since criminal cases require a higher standard of proof — of guilt beyond reasonable doubt — Villa-Ignacio argued the Sandiganbayan should dismiss his case as well.
The Sandiganbayan said Villa-Ignacio’s case is an exemption from the general rule that treats criminal and administrative proceedings separately.
Since the CA declared that Villa-Ignacio’s action did not constitute “betrayal of public trust” in the administrative case, the Sandiganbayan concluded that he was not in “bad faith” and could not thus be held liable for the criminal charges.
The antigraft court noted that good faith is a valid defense in falsification of documents cases, while perjury charges require that the assertion of falsehood be “willful and deliberate.”
“The absence of bad faith therefore negates the presence of criminal intent sufficient to sustain the instant charges for falsification and perjury,” read the resolution penned by Associate Justice Edgardo Caldona.
Villa-Ignacio was charged for answering in his 2005 personal data sheet that no administrative sanctions had ever been imposed on him.
It was learned, however, that SC reprimanded Villa-Ignacio in March 2001 for failing to resolve a motion for reconsideration in an annulment case he handled as a judge of Makati City Regional Trial Court Branch 143. JE
