Title
Coloma, Jr. vs. People
Case
G.R. No. 233152
Decision Date
Jul 13, 2020
Police officer convicted for unauthorized property purchase using public funds, favoring a contractor, causing government loss, and violating anti-graft laws.

Case Digest (G.R. No. 233152)
Expanded Legal Reasoning Model

Facts:

Background and Accusation On September 16, 2005, the Office of the Ombudsman found probable cause to charge Police Chief Superintendent (P/C Supt.) Dionisio B. Coloma, Jr. with three counts of violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The present case involved one of these counts, specifically the alleged unauthorized purchase of a 10,000-square-meter property in Bongao, Tawi-Tawi, using public funds.

Prosecution's Version
The prosecution alleged that Coloma, as Special Assistant to the Philippine Public Safety College (PPSC) President on Real Property Acquisition Projects, facilitated the unauthorized purchase of a property from Engr. Rolando Lim and his wife, Albia J. Lim, for P1,500,000. The purchase lacked proper authority, public bidding, and documentation, and the property was overpriced. Coloma also allegedly ensured the award of the construction project to A.C. Lim Construction (ACLC), a contractor associated with Engr. Lim, and transferred funds to the contractor’s account without proper documentation.

Defense's Version
Coloma claimed that PPSC’s budget officer certified funds for the project, and the property purchase was approved by PPSC President Ernesto B. Gimenez. He argued that his actions were in good faith and based on lawful authority.

Sandiganbayan's Findings
The Sandiganbayan found Coloma guilty, stating that he acted with manifest partiality and evident bad faith, causing undue injury to the government by overpaying for the property and giving unwarranted benefits to the contractor.

Issues:

Whether Coloma’s conviction for violation of Section 3(e) of R.A. No. 3019 should be upheld.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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