Facts:

• Josie Castillo-Co, Governor of the Province of Quirino, was found guilty of violating Section 3(g) of Republic Act (R.A.) No. 3019, the Anti-Graft and Corrupt Practices Act.
• The case began with a letter-complaint on June 27, 1997, by Junie E. Cua, Representative of the Province of Quirino and Chairman of the Committee on Good Government of the House of Representatives, submitted to the Office of the Ombudsman.
• The complaint alleged irregularities in the procurement of heavy equipment by the Provincial Government of Quirino from Nakajima Trading Co., Ltd.
• Gov. Co had entered into a loan agreement with the Philippine National Bank to purchase brand new heavy equipment, as per a resolution by the Sangguniang Panlalawigan of Quirino.
• On January 11, 1996, Gov. Co shifted and entered into an agreement to purchase reconditioned heavy equipment instead of new ones.
• The complaint further alleged that Gov. Co agreed to advance 40% of the total purchase price before delivery, violating Section 338 of the Local Government Code of 1991, and that the equipment was overpriced.
• Despite full payment, the Province of Quirino did not receive all the equipment within the agreed period.
• Graft Investigation Officer Germain G. Lim recommended prosecuting Gov. Co and dismissing the case against the Provincial Engineer, Virgilio Ringor.
• On September 2, 1998, an Information was filed before the Sandiganbayan charging Gov. Co with violating Section 3(g) of R.A. No. 3019.
• The Sandiganbayan found Gov. Co guilty, sentencing her to imprisonment and perpetual disqualification from public office.
• Gov. Co's motions for reconsideration were denied, leading to her petition for review.

Issue:

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Ruling:

• The Supreme Court denied the petition and affirmed the Sandiganbayan's decision, convicting Gov. Co of violating Section 3(g) of R.A. No. 3019.
• Gov. Co was sentenced to an indeterminate penalty of six years and one month as mini...(Unlock)

Ratio:

• The Court concluded that Gov. Co's actions caused gross and manifest disadvantage to the Province of Quirino.
• The elements of the offense under Section 3(g) of R.A. No. 3019 were satisfied:
  1. Gov. Co was a public officer.
  2. She entered into a contract on behalf of the government.
  3. The contract was grossly and manifestly disadvantageous to the government.
• The Court found that Gov. Co deviated from the authority granted by the Sangguniang Panlalawigan, which authorized the purchase of brand new equi...continue reading