Title
Balbedrin vs. Sandiganbayan
Case
G.R. No. 144950-71
Decision Date
Mar 22, 2007
Petitioners convicted for conspiring to falsify documents, enabling "ghost" deliveries and illegal disbursements of government funds in highway projects.
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Case Digest (G.R. No. 144950-71)

Facts:

Background of the Case

  • The case involves petitioners Blas Baldebrin and Perpetuo Lacea, who were convicted by the Sandiganbayan for violations of Section 3(e) of Republic Act (R.A.) No. 3019, the Anti-Graft and Corrupt Practices Act.
  • On August 8, 1981, the Tanodbayan (now Ombudsman) filed 110 Informations with the Sandiganbayan against various officials and private contractors for irregularities in the Ministry of Public Highways (MPH), now the Department of Public Works and Highways (DPWH).
  • Baldebrin was the administrative officer of the Negros Oriental Highway Engineering District (NOHED), while Lacea was a civil engineer and field supervisor.

Nature of the Charges

  • The charges stemmed from the falsification of public documents to facilitate "ghost" deliveries of materials for highway projects, resulting in illegal disbursements of government funds.
  • The Informations alleged that the accused, including Baldebrin and Lacea, conspired to falsify documents such as General Vouchers, Treasury Checks, Requests for Obligation of Allotment (ROA), and others, to misappropriate funds.

Investigation Findings

  • A Special Task Force, created by then President Ferdinand Marcos, investigated the irregularities in the MPH Region VII, including NOHED.
  • The investigation revealed that 26 vouchers were funded using fake supporting documents, with disbursements totaling P745,957.00 in 1977 and P1,321,664.44 in 1978.
  • The team found evidence of splitting requisitions, a practice prohibited under COA Circular No. 76-41, to circumvent government control measures.

Testimonies and Evidence

  • Delia Preagido, a state witness, testified that she and other officials conspired to siphon government funds using fake Letters of Advice of Allotment (LAAs) and manipulated accounting records.
  • Petitioners Baldebrin and Lacea denied involvement, claiming they performed their duties in good faith and that materials were actually delivered.

Sandiganbayan Decision

  • The Sandiganbayan found all accused guilty beyond reasonable doubt, ruling that they conspired to defraud the government.
  • Baldebrin was implicated for signing multiple Abstracts of Bids involving the same materials, suppliers, and projects on the same day, indicating splitting of accounts.
  • Lacea was found guilty for signing inspection reports and delivery receipts for materials that were never delivered.

Issue:

  1. Whether the Sandiganbayan erred in convicting Baldebrin and Lacea despite the prosecution's alleged failure to prove their guilt beyond reasonable doubt.
  2. Whether the petitioners' participation in the irregularities was indispensable to the conspiracy to defraud the government.

Ruling:

  • The Supreme Court denied the petition and affirmed the Sandiganbayan's decision, finding no reversible error in the conviction of Baldebrin and Lacea.
  • The Court held that the petitioners' roles in the irregularities were essential to the conspiracy, and their actions contributed to the defrauding of the government.

Ratio:

  1. Conspiracy and Indispensable Participation: The Court ruled that the petitioners' actions, though seemingly independent, were part of a concerted effort to defraud the government. Their roles in signing falsified documents and facilitating illegal disbursements were indispensable to the conspiracy.
  2. Splitting of Accounts: Baldebrin's signing of multiple Abstracts of Bids for the same materials and suppliers on the same day constituted splitting of accounts, a prohibited practice under COA Circular No. 76-41. His failure to notice or act on this glaring irregularity demonstrated gross negligence.
  3. Non-Delivery of Materials: The Court upheld the Sandiganbayan's finding that no materials were delivered, as evidenced by the falsified documents and testimonies of state witnesses. Lacea's claim of inspecting deliveries was insufficient to overturn this finding.
  4. Binding Factual Findings: The Court reiterated that factual findings of the Sandiganbayan are binding unless there is a showing of grave abuse of discretion or misapprehension of facts. Petitioners failed to establish any such exceptions.

Conclusion:

  • The Supreme Court affirmed the conviction of Baldebrin and Lacea, holding them liable for their roles in the conspiracy to defraud the government through falsification of documents and illegal disbursements of public funds.


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