G.R. No. 215042 - Field Investigation Office vs. Piano

The case involves the procurement of helicopter units by the Philippine National Police (PNP) in 2009, with an approved budget of P105,000,000.00.
The controversy arose when the supplier, MAPTRA Corporation, delivered one brand new Robinson R44 Raven II Light Police Operational Helicopter (LPOH) and two pre-owned Robinson R44 Raven I LPOHs instead of three brand new units as required by contract and NAPOLCOM specifications.
This deviation allegedly caused undue injury to the government and resulted in unwarranted benefits estimated at around P34,000,000.00.

The Field Investigation Office (FIO) filed a complaint before the Office of the Ombudsman against several respondents, including P/Dir. George Quinto Piano, the former Director for Logistics of the PNP.
An Inspection and Acceptance Committee (IAC), headed by respondent Piano as chairman among other respondents, was tasked with inspecting the helicopter deliveries.
The IAC’s inspection process was anchored on the WTCD Report No. T-2009-04A, prepared by a composite team from various PNP divisions, which evaluated the helicopters against the NAPOLCOM-approved technical specifications.

The endurance requirement of 3 hours had “no available data” and no corresponding remarks.
The air-conditioning requirement was not met as the units were noted as “Standard Helicopter” rather than air-conditioned.

Despite these discrepancies, the IAC Resolution No. IAC-09-045 stated that the delivered items were conforming to the approved specifications and were thus accepted for use by the PNP.

The Ombudsman found respondent Piano liable for serious dishonesty and conduct prejudicial to the best interest of the service, based on his role in signing the IAC Resolution which effectively concealed the discrepancies in the WTCD Report.
A joint resolution by the Ombudsman imposed administrative sanctions, including dismissal from service, forfeiture of retirement benefits, and perpetual disqualification from holding public office.
Respondent Piano filed motions and petitions, with the Court of Appeals (CA) initially exonerating him by relying on the WTCD Report and invoking the Arias doctrine, which suggests reasonable reliance on subordinate experts.
Ultimately, the petition for review on certiorari reached the Supreme Court, which revisited the factual issues given the conflict between the Ombudsman's findings and the CA decision.

WTCD Report No. T-2009-04A, which detailed the inspection findings, including noted non-conformities.
Memoranda and resolutions, such as the Memorandum by DRD Director Roderos and the IAC Resolution No. IAC-09-045 signed by respondent Piano.

The evidence underscores the failure of the IAC to adequately verify compliance with the NAPOLCOM specifications, despite clear indications in the inspection report to the contrary.

Whether the evidence, particularly the WTCD Report with its noted discrepancies, is sufficient to hold respondent Piano liable for serious dishonesty and conduct prejudicial to the best interest of the service.
Whether the reliance on the WTCD Report and subsequent Memorandum absolves respondent Piano from the duty to conduct a more thorough verification despite apparent deviations in the inspection findings.

Whether the Arias doctrine, which allows public officers to rely on recommendations from their subordinates, applies to the facts of this case without exception.
Whether any exceptional or additional circumstances warranted a higher degree of circumspection on the part of the IAC, especially given the specialized nature of the helicopters involved.

Whether respondent Piano, in his capacity as Chairman of the IAC, met the required standard of due diligence by verifying the discrepancies in the inspection report.
Whether his failure to investigate the issues noted (lack of data on endurance and non-conformance regarding the air-conditioning requirement) constitutes a distortion of truth in the performance of his official duties.