G.R. No. 191219 - Lihaylihay vs. People

The case arose following a special audit report submitted by the Commission on Audit which prompted the Philippine National Police (PNP) to conduct an internal investigation.
The investigation focused on the alleged ghost purchases of combat, clothing, and individual equipment (CCIE) worth P133,000,000.00.
The purchases were purportedly made from the PNP Service Store System (SSS) and delivered to the PNP General Services Command (GSC).

An Information was filed before the Sandiganbayan charging 10 PNP officers, including petitioners C/Insp. Virgilio V. Vinluan and SPO1 Ramon Lihay-Lihay, with violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
The accusatory portion alleged that on a series of dates in January 1992, the officers, through their official capacities, engaged in irregular transactions by:

Manipulating documents (e.g., Requisition and Invoice Vouchers [RIVs]) by erasing and superimposing dates to falsify the transaction period.
Signing incomplete certificates of acceptance and inspection forms despite the absence of evidence that the CCIE items were actually delivered, inspected, or distributed.

The fraudulent transactions were engineered by splitting the subject payment into several invoices, each amounting to P500,000.00, thereby avoiding higher-level scrutiny and remaining within the signing authority of certain officials.
As a result, the government sustained an undue injury amounting to approximately P8,000,000.00.

Four of the accused officers died during the pendency of the case, and one (Chief Supt. Jose M. Aquino) was dropped for lack of probable cause.
Ultimately, the case continued against Director Guillermo Domondon, Sr., Sr. Supt. Arnulfo Obillos, C/Insp. Virgilio Vinluan, and SPO1 Ramon Lihay-Lihay, with the latter three pleading not guilty while other issues involving absentee evidence persisted.
The records showed that despite the alleged receipt of CCIE items by GSC SAO Dante Mateo, no coherent documentary evidence existed to confirm actual delivery or proper inspection.

Tampered documents such as the RIVs with altered and superimposed dates indicating a different transaction period.
Inconsistencies in the Reports of Public Property Purchased, which failed to verify any actual inspection or delivery of items.
A series of 16 checks, all dated January 15, 1992, payable to PNP SSS, reinforcing the anomaly in the processing of the transactions.

Despite the evidence indicating discrepancies, petitioners certified and approved the documents, thereby tacitly endorsing the irregularities.

Whether the conviction of petitioners Vinluan and Lihay-Lihay for the violation of Section 3(e) of RA 3019 was proper.
Whether the actions and signatures affixed on defective documents amounted to evidence of manifest partiality, evident bad faith, or gross inexcusable negligence.

Whether issues raised regarding the sufficiency of evidence and the credibility of the transactions could be re-examined, given that only questions of law (and not questions of fact) are permissible in appeals from the Sandiganbayan.

Whether the concerted actions of the accused, particularly the splitting of transactions and the uncritical approval of irregular documents, sufficiently established a conspiracy among petitioners.