Title
Bernardino vs. People
Case
G.R. No. 170453
Decision Date
Oct 30, 2006
Former Municipal Mayor and members of the Pre-Qualification Bid and Awards Committee are convicted for falsification of public documents in connection with a public bidding, with one member acquitted due to lack of evidence and another member convicted for signing false minutes.
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Case Digest (G.R. No. 170453)

Facts:

  • Petitioners: Nestor A. Bernardino (former Municipal Mayor and PBAC Chairman), Eugelio G. Barawid (Municipal Treasurer and PBAC member), Celedonia N. Tomas (PBAC's acting Secretary).
  • Other PBAC members: Municipal Councilors Ernesto T. Mateo and Benito A. Rillo, Municipal Planning and Development Coordinator Efren N. Fronda, Municipal Budget Officer Abraham P. Coloma, Municipal Engineer Jose F. Mateo, Municipal Accountant Renato L. Esquivel, NGO representatives Paulino G. Quindara and Luis F. Rendon, Jr.
  • Date of alleged public bidding: December 8, 1997.
  • Project: Construction of the public market extension in Guimba, Nueva Ecija.
  • Initial awardee: Mascom Design and Engineering International (MASCOM).
  • Subsequent actions: Newly elected Mayor Jose Lucius Pocholo Dizon conducted another bidding, awarding the project to KYRO Builder.
  • Resulting complaint: MASCOM filed a complaint against Mayor Dizon and Barawid.
  • Affidavits: Several PBAC members claimed no public bidding took place on December 8, 1997.
  • Charges: Falsification of public documents against PBAC members.
  • Sandiganbayan's decision: Found petitioners guilty, sentenced them to imprisonment and fines.
  • Motions for new trial: Denied, leading to consolidated petitions before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court acquitted petitioners Nestor A. Bernardino and Eugelio G. Barawid due to reasonable doubt but affirmed the conviction of Celedonia N. Tomas with modifications to her sentence....(Unlock)

Ratio:

  • Presumption of innocence: Emphasized in criminal prosecutions.
  • Burden of proof: Prosecution must prove guilt beyond reasonable doubt.
  • Evidence: Affidavits of PBAC members were insufficient as they were based on opinions, not personal knowledge.
  • Testimonies: COA representative Ronquillo and Mayor Dizon lacked personal knowledge.
  • Absence of PBAC members: Did not conclusively prove no bidding took place.
  • Equipoise rule: Applied, favoring the presumption of innocence.
  • Tomas's liability: Found liable for falsification as she signed the "...continue reading

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