Herrera v. Sandiganbayan

Summary

This case involves the criminal conviction of a government employee for falsifying a public document related to procurement bidding. Naomi Herrera, a Management and Audit Analyst IV, was convicted of falsification under Article 171 of the Revised Penal Code for signing Resolution No. 007 which falsely stated that certain companies participated in typewriter procurement bidding when they had not. She attended the Bids and Awards Committee meeting as substitute for her superior. The Sandiganbayan found all elements of falsification proven and sentenced her to imprisonment and perpetual disqualification from public office. The Supreme Court affirmed, holding that its review was limited to questions of law and that the Sandiganbayan's factual findings were supported by evidence. The case demonstrates that public officers can be held criminally liable for falsification even when acting as substitutes, and that good faith is not a defense when the elements of the crime are established.