G.R. No. 209073-74 - Joseph Cedrick O. Ruiz vs. People and Hon. Sandiganbayan

Joseph Cedrick O. Ruiz, then Mayor of Dapitan City (1998-2001), was charged with violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) and Malversation under Article 217 of the Revised Penal Code.
The offenses charged concerned his alleged role in the illicit withdrawal and misappropriation of One Million Pesos (PHP 1,000,000.00) from the Confidential and Intelligence Fund (CIF) for Fiscal Year 2001, which was under his custody and control as mayor.
The funds were allegedly taken with the aid of Police Inspector Pepe E. Nortal, who was designated as a state witness and discharged later in the proceedings.

The accused, while performing his official functions, conspired with Nortal to allow the cash advance of PHP 1,000,000.00 from CIF, which was meant for the city government’s official use.
After encashment, the amount was allegedly used for their personal benefit, causing undue injury to the city government.

Ruiz refused to enter a plea and a plea of not guilty was entered on his behalf.
Trial ensued with testimony from:

Nortal testified that Ruiz instructed him to request and facilitate the withdrawal of the entire CIF amount on his behalf, despite Nortal’s initial refusal due to Ruiz’s unliquidated cash advances.
Ruiz personally received the funds after Nortal and the city’s private secretary encashed the check.
Starting with a letter of denial from Torres due to procedural violations, Ruiz actively ensured the release of the funds through notes and directives.
The request was made shortly after the 2001 elections and just weeks before Ruiz’s term ended.

Ruiz claimed he authorized the cash advance to address post-election violence and criminality.
He denied meeting Nortal at the Dapitan Resort Hotel or receiving the fund, stating he was sick and went home early on May 30, 2001.
Presented witnesses corroborated his alibi and questioned the process.

Ruiz was convicted of violation of Section 3(e) of RA 3019 and Malversation under Article 217 of the RPC.
The court found he acted with evident bad faith and caused undue injury to the city government.
The elements of both crimes were found proven beyond reasonable doubt.

Whether the Sandiganbayan erred in convicting Ruiz based on the evidence and the law.
Whether the denial of the motion for new trial was proper.
Whether Ruiz’s guilt for violation of RA 3019 and Malversation was established beyond reasonable doubt.