Case Digest (G.R. No. 229265)
Case Digest (G.R. No. 229265)
Facts:
Silvino B. Matobato, Sr., petitioner, vs. People of the Philippines, respondent; consolidated with Walter B. Bucao and Cirila A. Engbino, petitioners, vs. Honorable Sandiganbayan‑Special Fifth Division and People of the Philippines, respondents, G.R. Nos. 229265 and 229624, February 15, 2022, Supreme Court First Division, Lopez, M., J., writing for the Court.In 1994 the Sangguniang Bayan of the Municipality of Pantukan, Compostela Valley passed Resolution No. 164, Series of 1994 authorizing Municipal Treasurer Silvino B. Matobato, Sr. to transfer municipal time deposits from the Land Bank of the Philippines (LBP) to Davao Cooperative Bank (DCB). Pursuant to that resolution, Silvino opened a time deposit account with DCB and deposited municipal funds from 1994 to 1998. DCB subsequently became insolvent and was placed under receivership in 1998; the Municipality was thereafter unable to withdraw the deposited sums.
The Commission on Audit (COA), in its 1998 Annual Audit Report, found that the Sangguniang Bayan treated those funds as idle funds but had not allocated them to municipal projects; COA recommended filing criminal and administrative charges against the municipal officials involved and cited COA Circular No. 92‑382 (Secs. 21–22) on time deposits of idle funds. The Office of the Ombudsman filed an Information for violation of Section 3(e) of Republic Act No. 3019 against Silvino and several Sangguniang Bayan members, including Walter B. Bucao and Cirila A. Engbino, docketed as Sandiganbayan Crim. Case No. SB‑10‑CRM‑0015, charging conspiracy and gross inexcusable negligence in authorizing Resolution No. 164 and the transfers to DCB.
After trial, the Sandiganbayan Special Fifth Division acquitted Silvino, Walter and Cirila (and co‑accused) for lack of proof beyond reasonable doubt in a Decision dated September 20, 2016 and a Resolution dated January 11, 2017. Although it found the prosecution failed to prove gross and inexcusable negligence necessary for conviction under RA 3019 Sec. 3(e), the Sandiganbayan nonetheless held the three accused civilly and solidarily liable to indemnify the Municipality for unrecovered funds amounting to P9.25 million, concluding that their conduct amounted to negligence under a preponderance‑of‑evidence standard.
The petitioners filed consolidated Petitions for Review on Certiorari (Rule 45) assailing the Sandiganbayan Decision and Resolution — G.R. No. 229624 (challenging the Decision dated September 20, 2016) and G.R. No. 229265 (challenging the Resolution dated January 11, 2017). Silvino contended he could not be held civilly liable while DCB remained under liquidation and argued potential future recovery from DCB would unjustly enrich the Municipality; Walter and Cirila argued the evidence did not preponderantly support civil liability and invoked the presumption of regularity in their official acts.
Issues:
- Can the Sandiganbayan properly impose civil and solidary liability on petitioners despite their criminal acquittal?
- Did petitioners fail to exercise the required due diligence and thus incur civil liability for the municipality’s unrecovered funds, or does the presumption of regularity shield them?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)