Case Summary (G.R. No. 259815)
Applicable Law
The charges against Alpay are grounded in Article 171 of the Revised Penal Code (RPC), which pertains to the Falsification by Public Officer, Employee, or Notary or Ecclesiastic Minister.
Factual Background
Alpay faced accusations in thirty-nine Informations that arose from the alleged falsification of disbursement vouchers and documents tied to a government program initiated by then-President Gloria Macapagal-Arroyo. The program aimed to provide financial assistance to small and medium enterprises (SMEs) through the allocation of one million pesos per municipality. Alpay was mandated to distribute this aid specifically for the procurement of necessary equipment for selected farmers and fishermen.
On June 30, 2004, coinciding with his term's end, Alpay convened local beneficiaries to deliver funds in conjunction with the procurement of equipment. However, the transactions came under scrutiny as alleged discrepancies were reported, suggesting that the funds were misallocated and that proper procurement procedures were not followed.
Court Proceedings
Upon being arraigned, Alpay entered a plea of not guilty. The Sandiganbayan subsequently acquired testimonies from various witnesses, yielding conflicting accounts regarding the authenticity of the vouchers and the recipients' participation. The municipal accountant and treasurer offered testimony implicating Alpay's involvement in circumventing established procedures leading up to the alleged falsifications.
Ruling of the Sandiganbayan
The Sandiganbayan's April 24, 2018 Decision acquitted Alpay on multiple counts but found him guilty on others, sentencing him to an indeterminate penalty and fines for falsification. This Decision illustrated the court's reliance on circumstantial evidence, considering Alpay's role as a public officer, and concluded that he exploited his official position to facilitate the alleged crimes.
Petitioner's Arguments
Alpay contended that the Sandiganbayan made grave errors in its findings, insisting that he did not intervene in the falsification of documents nor possessed the obligation to prepare them as the former mayor. Furthermore, he challenged the trial court's refusal to consider his motion for reconsideration, arguing that it had merit and should have been heard regardless of his counsel's absence.
Respondent's Position
The prosecution contended that Alpay's position of authority allowed him to influence the issuance of funds to specific beneficiaries, thereby implicating him in the irregularities. The prosecution emphasized that the corroborating testimonies of the witnesses carried more weight than Alpay's denials.
Court's Analysis
The Court reiterated that its jurisdiction over appeals from the Sandiganbayan is confined to questions of law, thus limiting its examination of the factual determinations made by the lower court. The Sandiganbayan had found these determinations justified based on circumstantial evidence depicting Alpay's direct involvement and manipulation of the financial assistance program.
In thoroughly
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Case Overview
- Petitioner Cesar P. Alpay, former Municipal Mayor of Unisan, Quezon, was accused in thirty-nine (39) Informations under Article 171 of the Revised Penal Code (RPC).
- The accusations involved the falsification of disbursement vouchers related to financial assistance provided under the "Isang Bayan, Isang Produkto, Isang Milyong Piso" program.
- The case was brought before the Sandiganbayan, Fifth Division, resulting in a mixed ruling of acquittals and convictions.
Background of the Case
- Executive Order No. 176 was issued by then President Gloria Macapagal-Arroyo in 2003, allocating financial assistance to small and medium enterprises (SMEs) through municipalities.
- In 2004, Alpay planned to use the allocated Php 1,000,000.00 for distributing cash to farmers and fishermen to purchase equipment.
- On June 30, 2004, Alpay allegedly distributed cash to 42 beneficiaries, who were supposed to use it for purchasing hand tractors and motor engines.
Allegations
- The charges against Alpay involved falsifying disbursement vouchers to create the illusion that beneficiaries received cash assistance when, in fact, they received equipment not acquired through proper bidding procedures.
- The prosecution presented evidence indicating that Alpay signed vouchers certifying that the disbursement was necessary and lawful, despite procedural irregularities.
Proceedings and Testimonies
- Upon arraignment, Alpay pleaded not guilty to all charges.
- Testimonies from municipal accountant Teresita Musca and mun