G.R. No. 205576 - Escobar vs. People

This is a Consolidated Petition for Review on Certiorari challenging the Sandiganbayan’s Decision (dated August 22, 2012) and Resolution (dated January 8, 2013) in Criminal Case No. 28293.
The petitioners—Miguel D. Escobar, Eugene L. Alzate, Perla C. Maglinte, Cesar M. Cagang, and Vivencia S. Telesforo—face criminal liability in relation to the misappropriation of public funds.
The crimes charged include estafa through falsification of public documents and malversation, committed by public officers of the Provincial Government of Sarangani.

An Information alleged that on or around May 27, 2002 in Sarangani, public officials conspired in the misappropriation of ₱300,000.00 from public funds.

The funds, withdrawn from the account of the Province of Sarangani, were intended as financial assistance purported to have been granted to the Malungon Market Vendors Association.
The supporting documents, notably a Disbursement Voucher and its accompanying letter request and Project Proposal, were allegedly falsified to create the appearance of a legitimate transaction.

The creation of fictitious documents that purportedly showed a request for financial assistance, including a letter dated May 20, 2002 and a Project Proposal signed by an alleged “Nema Tamayo.”
The manipulation of documents such that the disbursement voucher bore the signatures of key officials, including Governor Escobar, Vice Governor (through his representative), and certifying signatures of Telesforo and Cagang.
The endorsement and subsequent encashment of a Development Bank of the Philippines (DBP) check, which was improperly released for personal use.

During trial proceedings, the accused public officers pleaded not guilty; however, evidence revealed a complex scheme:

Witness testimonies (notably that of Mary Ann Gadian and Joy/Tatang Tangan) detailed instructions by accused Zoleta and Maglinte related to the preparation and presentation of the falsified supporting documents.
Testimonies indicated that instructions were given to “double” or add extra sums (e.g., an additional ₱10,000.00) to expedite processing, implicating a conspiracy.

Petitioner Maglinte was alleged to have verified and reviewed the falsified documents and participated in forwarding them for approval.
Petitioner Alzate was implicated as a primary beneficiary; his immediate action in receiving ₱200,000.00 for his wedding expenses was highlighted.
Petitioners Escobar, Telesforo, and Cagang, though signing the voucher and possessing custody of the funds, were charged with malversation, in view of their failure to exercise due diligence over the disbursement scheme.
Co-accused Zoleta, whose instructions and supervisory role in document preparation were repeatedly mentioned, was found to have directed the entire fraudulent scheme.

The supporting documents lacked proper approvals, were not compliant with COA Circular No. 96-003, and contained anomalies (e.g., the misnaming of the payee).
Investigations revealed that the funds were disbursed despite these irregularities, resulting in their misappropriation for personal use and benefit.

Following the conviction and imposition of penalties ranging from prision mayor to reclusion temporal—with attendant fines—the petitioners filed Motions for Reconsideration which were denied.
The petitioners later challenged the Sandiganbayan findings on various grounds including the issues of due process, reliance on subordinate actions (Arias doctrine), and the applicability of conclusiveness of judgment (res judicata) in criminal cases.
The consolidated issues then advanced to the Supreme Court for review.

Whether the Sandiganbayan erred in convicting petitioners Eugene L. Alzate and Perla C. Maglinte of estafa through falsification of public documents by failing to establish that they acquired juridical possession of the funds or had a duty to return them.
Whether the trial court improperly applied or disregarded the Arias doctrine, specifically the reliance of heads of offices on the representations or actions of their subordinates.
Whether petitioner Eugene L. Alzate was denied due process when his motion for a new trial and request to present additional witnesses were dismissed on procedural grounds, thereby affecting his right to be heard.
Whether petitioners Miguel D. Escobar and Vivencia S. Telesforo can be deemed accountable public officers under the relevant provisions, particularly given their roles and the custody of the disbursed funds.
Whether the Sandiganbayan erred in basing the convictions primarily on the testimony of witnesses who were also active participants in the transaction, and whose credibility might be in question.
Whether the doctrine of conclusiveness of judgment (res judicata) applies in criminal prosecutions in this case, especially in relation to the earlier Criminal Case No. 28331 involving similar issues.