G.R. No. 97214 - Navallo vs. Sandiganbayan

On May 11, 1978, an information was filed in the Court of First Instance of Surigao del Norte (Crim. Case No. 299) charging Ernesto Navallo, Collecting and Disbursing Officer of Numancia National Vocational School, with violation of Article 217(4) of the Revised Penal Code for misappropriating ₱16,483.62 in public funds. A warrant of arrest and two alias warrants were issued but the accused remained at large.
On December 10, 1978, Presidential Decree No. 1606 took effect, creating the Sandiganbayan with original and exclusive jurisdiction over Title VII RPC offenses by public officers.

Ernesto Navallo was arrested on November 15, 1984, released on provisional liberty after posting a property bail bond, and arraigned before the RTC on July 18, 1985, pleading not guilty.
On May 22, 1986, upon the prosecution’s motion, the RTC transferred the case to the Sandiganbayan (Crim. Case No. 13696). A dispute arose whether his prior RTC arraignment barred the transfer; the Ombudsman held otherwise.

The Sandiganbayan issued a new warrant of arrest; the RTC Clerk certified the earlier bail, which was found defective. On August 30, 1989, a new bail bond was approved and transmitted.
Navallo’s motion to quash based on lack of jurisdiction and double jeopardy was denied on September 15, 1989. He was arraigned on October 20, 1989, pleaded not guilty, and trial commenced.

Prosecution Evidence: Provincial Auditor Antonio Espino’s preliminary audit (January 27, 1978) revealed a shortage of ₱16,483.62. State Auditor Dulguime confirmed the shortage on January 30, 1978, demanded restitution, and prepared a report—subsequently lost due to typhoon damage.
Defense Evidence: Navallo testified he assumed full duties only in 1978; Cesar Macasemo, his predecessor, shared custody of the vault and pressured him to sign the audit report; claimed the shortage represented Macasemo’s unliquidated cash advances; alleged personal grudge by Espino.

On November 8, 1990, the Sandiganbayan convicted Navallo of malversation, imposed an indeterminate sentence of 10 years 1 day to 16 years 5 months 11 days, perpetual special disqualification, a fine of ₱16,483.62, and ordered restitution.
The Sandiganbayan denied reconsideration on February 5, 1991. Navallo appealed to the Supreme Court raising four issues.

Whether the Sandiganbayan acquired jurisdiction despite the pre-PD 1606 information filed in the CFI.
Whether arraignment by the RTC constituted double jeopardy.
Whether Navallo was under custodial investigation when he signed the audit certification.
Whether the prosecution proved guilt beyond reasonable doubt.