Title
Coloma, Jr. vs. Sandiganbayan
Case
G.R. No. 205561
Decision Date
Sep 24, 2014
Coloma, a public officer, misrepresented RTS 9 project progress and costs, causing undue injury to PPSC. Convicted under Anti-Graft Law, affirmed by Supreme Court.

Case Digest (G.R. No. 205561)
Expanded Legal Reasoning Model

Facts:

  • Parties and Context
    • Petitioner: Dionisio B. Coloma, Jr., then Director of the Philippine National Police Academy (PNPA) and Special Assistant & Action Officer to the Director, Logistics and Installation Services (LIS) of the Philippine Public Safety College (PPSC).
    • Respondents: The Sandiganbayan (Third Division) and the People of the Philippines.
    • The case arises from irregularities in the implementation and reporting of the construction of the RTS 9 Annex in Bongao, Tawi-Tawi, a project funded by public funds.
  • Background and Project Development
    • Assignment and Site Selection
      • In November 1999, Coloma was designated to assist in identifying a suitable site for the Philippine National Police Regional Training Site 9 Annex (RTS 9).
      • After several site inspections carried out in 2002 by the PPSC team led by President Ernesto B. Gimenez, a four-hectare lot (planted with coconut and fruit-bearing trees) originally owned by Juaini Bahad and subsequently sold to Albia Lim was chosen.
    • Project Plans and Funding
      • The PPSC Engineering Division, headed by Engineers Dosmedo G. Tabrilla and Jerome Vacnot, prepared the graphical layout plan.
      • The design included a fifty-capacity barracks, a one-unit classroom, land development, and an administration building.
      • The layout plan was approved by PPSC President Gimenez.
      • Funding was sourced from the Congressional Development Fund (CDF) appropriated by Tawi-Tawi Representative Nur Jaafar, with disbursements made to New Alems Enterprise (for materials) and A.C. Lim Construction (as the labor supplier).
  • Coloma’s Role and Reported Developments
    • Administrative and Supervisory Role
      • Coloma, acting in his dual capacity as Director of the PNPA and Special Assistant at PPSC, played a role in both site selection and the oversight of financial and administrative matters related to the project.
      • His involvement extended from the negotiation and inspection phases to a subsequent responsibility in monitoring construction progress.
    • After Mission Report
      • On October 10, 2001, Coloma submitted an After Mission Report which stated that:
        • The land development had been completed 100% (referring strictly to the site of the administrative building and classroom).
ii. The construction of the administration building was 90% complete. iii. The construction of the fifty-capacity barracks and a classroom had commenced and was projected for completion by December 15, 2001.
  • He attached a Deed of Donation purportedly evidencing the transfer of the lot to the PPSC.
  • Investigation and Discovery of Irregularities
    • Initiation of Inquiry
      • After Coloma’s report, PPSC President Atty. Ramsey Lapuz Ocampo, his successor, initiated an investigation into the progress and financial management of RTS 9.
      • SPO4 Gilbert Concepcion was tasked to conduct an on-site inspection and gather evidence regarding the project’s implementation.
    • Findings from the Investigation
      • Several irregularities were noted, including:
        • The “100% completion” of land development referred only to the portion where the administrative building and classroom were erected.
ii. There was no evident construction of the fifty-capacity barracks despite Coloma’s claim that work had commenced. iii. An inconsistency in the reported cost: while Coloma stated the project cost was approximately P5,727,278.59, the actual cost assessment yielded around P3,150,000.00. iv. Discrepancies in the declared value of the property, with Coloma estimating it at P1,500,000.00 versus a valuation of approximately P9,730.00 per hectare per a Tawi-Tawi ordinance.
  • Documentary evidence and witness testimonies (including those of Engr. Vacnot, SPO4 Concepcion, Accountant Jimena Piga, Architect Peter Razon Viduya, and Engr. Tabrilla) substantiated these irregularities.
  • Charging and Trial Proceedings
    • Indictment and Specific Charges
      • On September 15, 2006, Coloma was indicted and charged with violating Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) for causing undue injury to the PPSC amounting to about P2,500,000.00.
      • The charge centered on his purported misrepresentation by falsely reporting the progress and cost of the project, which led to a loss of control over the use of public funds.
    • Trial Developments
      • Coloma pleaded not guilty, shifting the debate over the factual findings and the weight of the evidence.
      • The prosecution presented extensive testimonial and documentary evidence showing discrepancies between Coloma’s report and the actual state of the project.
      • The defense maintained that Coloma’s observations were factual and that he merely followed instructions from his superior, thereby denying any malicious intent or gross negligence.

Issues:

  • Whether Coloma’s conviction under Section 3(e) of R.A. No. 3019 was proper given the discrepancies between his report and the actual state of RTS 9.
    • Specifically, did Coloma’s misrepresentation of the construction progress and cost constitute manifest partiality, evident bad faith, or gross inexcusable negligence?
    • Whether the reliance on the testimonies of prosecution witnesses (notably Engr. Vacnot and Engr. Tabrilla) was justified in establishing the undue injury to the PPSC.
    • Whether questions that are essentially factual in nature—such as the credibility of witness statements and the actual progress of the construction project—can be reappraised on appeal.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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