Nizurtado v. Sandiganbayan

Summary

This case involves the conviction of Barangay Captain Felix Nizurtado for the complex crime of malversation through falsification of public document. Nizurtado received P10,000 in public funds for a barangay livelihood program but falsified a council resolution to make it appear that T-shirt manufacturing was approved as the project when no such meeting occurred. He then distributed the funds as personal loans to council members instead of using them for the intended purpose. The Sandiganbayan convicted him, and the Supreme Court affirmed the conviction but reduced the sentence, recognizing three mitigating circumstances including voluntary surrender, restitution, and lack of intent to commit such grave wrong. The case establishes important precedents on complex crimes, penalty computation under the Indeterminate Sentence Law, and the elements of both malversation and falsification of public documents by public officers.