Case Digest (G.R. No. 191611-14)
Facts:
The case involves petitioners Librado M. Cabrera and Fe M. Cabrera, who were public officials in Taal, Batangas. They were charged with violations of the Anti-Graft and Corrupt Practices Act (R.A. No. 3019) in four separate criminal cases (Criminal Cases Nos. 27555, 27556, 27557, and 27558). The events leading to the charges occurred between 1998 and 1999. Librado served as the Municipal Mayor, while Fe was also a Municipal Mayor during the relevant period. The charges stemmed from their actions in making direct purchases of medicines from Diamond Laboratories, Inc. (DLI), a company owned by Librado's relatives, without conducting public bidding, which allegedly resulted in undue benefits to DLI and caused injury to the Municipality of Taal. The total amount involved in these purchases was P503,920.35 for Librado and P1,042,902.46 for Fe. Additionally, both petitioners were accused of illegally reimbursing themselves for travel expenses incurred during unauthorized trips ...
Case Digest (G.R. No. 191611-14)
Facts:
Background: Petitioners Librado M. Cabrera and Fe M. Cabrera, former mayors of Taal, Batangas, were charged with violating Section 3(e) of Republic Act (R.A.) No. 3019, the Anti-Graft and Corrupt Practices Act, in four consolidated criminal cases.
Criminal Case No. 27555: Librado and Luther H. Leonor, then Municipal Councilor, were accused of making direct purchases of medicines from Diamond Laboratories, Inc. (DLI), owned by Librado’s relatives, without public bidding, giving DLI unwarranted benefits. The total cost was P503,920.35.
Criminal Case No. 27556: Librado was accused of reimbursing P27,651.83 for unauthorized travel expenses, causing undue injury to the municipality.
Criminal Case No. 27557: Fe and Leonor were accused of making direct purchases of medicines from DLI without public bidding, totaling P1,042,902.46, giving DLI unwarranted benefits.
Criminal Case No. 27558: Fe was accused of reimbursing P170,987.66 for unauthorized travel expenses, causing undue injury to the municipality.
Defenses:
- Petitioners claimed the purchases were emergency purchases and fell under exceptions to public bidding.
- They argued that travel expenses were supported by receipts and certifications, and they had verbal and later written permission from the governor.
Issue:
- Whether the lack of public bidding in the procurement of medicines constituted giving unwarranted benefits to DLI.
- Whether the permission required for travel reimbursements under the Local Government Code (LGC) must be in writing.
- Whether the reimbursements of travel expenses caused undue injury to the government.
Ruling:
The Supreme Court affirmed the Sandiganbayan’s decision, finding petitioners guilty beyond reasonable doubt of violating Section 3(e) of R.A. No. 3019.
Criminal Cases Nos. 27555 and 27557: The Court ruled that petitioners failed to comply with the legal requirements for emergency purchases and direct procurement from manufacturers. The absence of public bidding gave DLI unwarranted benefits, showing manifest partiality.
Criminal Cases Nos. 27556 and 27558: The Court found that petitioners did not secure written permission for their travels before departure, as required by the LGC. Their subsequent approval from the governor did not cure the defect. The reimbursements caused undue injury to the municipality.
Penalty: Petitioners were sentenced to imprisonment ranging from six years and one month to ten years for each charge, with perpetual disqualification from public office. They were also ordered to reimburse the municipality for the travel expenses.
Ratio:
Public Bidding Requirement: Public bidding is mandatory under the LGC to ensure transparency and fairness in government transactions. Deviations must strictly comply with legal requirements. Petitioners failed to prove their purchases fell under valid exceptions, rendering the procurement irregular.
Manifest Partiality: Awarding contracts to relatives without public bidding demonstrated favoritism, violating Section 3(e) of R.A. No. 3019.
Travel Permissions and Reimbursements: The LGC requires written permission for travel before departure. Petitioners’ failure to comply made their travels unauthorized, and their reimbursements constituted bad faith and gross inexcusable negligence.
Undue Injury to Government: The unauthorized disbursement of public funds for unjustified expenses caused financial harm to the municipality, fulfilling the element of undue injury under the Anti-Graft Law.