Title
Supreme Court
People vs. Amelia R. De Pano, Angelito A. Rodriguez, Noel G. Jimenez, and Jose Joel B. Baldeo
Case
G.R. No. 254639
Decision Date
Oct 21, 2024
The case involved accused public officers found guilty of violating the Anti-Graft and Corrupt Practices Act but were acquitted on appeal due to lack of evident bad faith while still liable for civil indemnification.

Case Digest (G.R. No. 79734)
Expanded Legal Reasoning Model

Facts:

  • Parties and Charges
    • Accused-appellants Noel G. Jimenez and Angelito A. Rodriguez, together with Amelia R. De Pano and Jose Joel B. Baldeo, were charged with violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) concerning the construction of a perimeter fence at Palili Elementary School in Palili, Samal, Bataan.
    • The Information alleged that the accused, in their respective positions as Provincial Engineer, Assistant Provincial Engineer, Field Engineer IV, and a private contractor, conspired to cause undue injury to the Provincial Government of Bataan by falsely certifying the completion of the perimeter fence, resulting in payment of PHP 253,725.00 for an incomplete project.
    • The case against accused Baldeo was dismissed following submission of his death certificate.
  • Proceedings
    • The accused pleaded not guilty during arraignments and stipulated certain facts during the pre-trial conference, including their official positions and signatures on key documents like the Certification and Accomplishment Report dated March 17, 2004.
    • Trial ensued where prosecution witnesses included former school personnel, COA auditors, the Department of Education regional supervisor, and provincial government officials.
  • Prosecution's Evidence
    • Testimonies established that while blocks for the fence were delivered, the perimeter fence was never constructed as corroborated by ocular inspections.
    • COA audit reports revealed no fence was built, contradicting the certifications issued by the accused.
    • Financial documents showed payment was made to Baldeo Construction for the incomplete project.
    • Attempts to obtain a reply from the accused-appellants regarding audit observations went unanswered.
  • Defense's Version
    • The defense claimed the accused signed documents by honest mistake, confusing the perimeter fence project with a separate Day Care Center project.
    • Accused Engr. De Pano stated she did not personally inspect the project and relied on subordinates’ verification before signing.
    • The accused-appellants asserted no bad faith or manifest partiality, but rather clerical errors and bureaucratic procedures led to the signatures on the questionable documents.
    • A key defense affidavit by Gov. Enrique T. Garcia, Jr. expressed disinterest in pursuing the complaint against them.
  • Sandiganbayan Decision
    • Found accused-appellants Jimenez and Rodriguez guilty beyond reasonable doubt of violation of R.A. 3019 Section 3(e), sentencing them to imprisonment and loss of retirement benefits.
    • Acquitted Engr. De Pano for failure of the prosecution to prove guilt beyond reasonable doubt.
    • Ordered accused De Pano, Rodriguez, and Jimenez to indemnify the Provincial Government of Bataan PHP 253,725.00 jointly and severally.

Issues:

  • Whether the Sandiganbayan has jurisdiction over the accused-appellants despite their salary grades being below 27.
  • Whether the Sandiganbayan erred in finding the accused-appellants guilty beyond reasonable doubt of violating Section 3(e) of R.A. No. 3019.
  • Whether the Sandiganbayan erred in its finding of conspiracy among the accused-appellants.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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