Valenton, Francis Angelo T.

Criminal Law 2

1S

Oani vs. People (G.R. No. 139984)

Facts: The petitioner is Leopoldo Oani. The respondent is the People of the Philippine. In the
case at bar, the herein petitioner was a Principal of Panbo High School in Panabo, Davao del
Norte. During the school year 1988-1989m he implemented the free secondary school program
of the government. During the said period, the said school received P648,532.00 from the
Department of Education, Culture and Sports (DECS) for Maintenance and Other Operating
Expenses (MOOE). The amount of P441,439.13 was earmarked for the purchase of various
supplies, materials and equipment. In lieu of such budget, the petitioner acquired 15 units of fire
extinguishers, among others, form a certain company called Powerline as owned by a certain
Francisco Cunanan. It was found out that such purchase was not done in accordance with RA
3019, or the government procurement act. However, the certificate made by Cunanan said
otherwise, saying that they complied with the rules and regulation with respect to procuring such
fire extinguishers.

Issue: Is the Certificate issue by Cunanan valid.

Held: The Supreme Court said that the certification issue by Cunanan of Powerline
Manufacturing Industry, stating that they procured such transaction legally, was false. According
to the Supreme Court, such certification as adduced by the petitioner as evidence is a clear
violation under the last paragraph of Article 172 of the Revised Penal Code for using such
falsified document as evidence in the court.