Case Summary (G.R. No. 81563)
Petitioner and Respondent
Petitioners: Amado C. Arias and Cresencio D. Data
Respondent: Sandiganbayan (En Banc)
Key Dates
• February 27, 1978 – Genuine tax declaration values riceland at ₱5/m²
• April 20, 1978 – Deed of sale executed for 19,004 m² at ₱80/m²
• October 23, 1978 – Voucher for payment (₱1,520,320) pre-audited by Arias
• November 16, 1987 – Sandiganbayan conviction for conspiracy and causing undue injury
• December 19, 1989 – Supreme Court decision
Applicable Law
• Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), Section 3(e)
• New Civil Code, Articles 1473–1475 (negotiated purchase)
• Government Auditing Code (audit powers and duties)
• 1973 Philippine Constitution (in force at time of decision)
Factual Background
The Bureau of Public Works negotiated the acquisition of a 19,004 m² portion of riceland in Pasig for the Mangahan Floodway. Municipal records assessed it at ₱5/m², but the Deed of Sale, supported by falsified tax declarations and certifications, classified it as residential and set the purchase price at ₱80/m². Supporting documents included counterfeit copies of Tax Declarations Nos. 47895 and 49948, a forged municipal treasurer’s certification, and altered technical descriptions. The lot owner’s attorney-in-fact, Natividad C. Gutierrez, presented these papers, and the project committee handled negotiations and paperwork. Arias, as district auditor, approved the voucher for payment without verifying authenticity; Data, as district engineer, signed the deed of sale prepared by his committee.
Procedural History
Six officials were charged with conspiring to cause undue injury to the Government under RA 3019 by approving and processing an overpriced land acquisition. The Sandiganbayan convicted all six, sentencing each to three to six years’ imprisonment, perpetual disqualification, and joint indemnification of ₱1,425,300. Arias and Data appealed to the Supreme Court.
Majority Decision
The Supreme Court granted the petitions of Arias and Data, setting aside their convictions and acquitting them for reasonable doubt. Key holdings:
- Quantum of Evidence Insufficient – There was no direct proof linking either petitioner to knowing, personal participation in the alleged conspiracy. Inferences based solely on signatures and roles in approval processes fail to meet the standard of proof beyond reasonable doubt.
- Conspiracy Theory Overextended – Recognizing the risk of sweeping innocent officials into criminal liability, the Court stressed that conspiracy requires evidence of deliberate, knowing agreement, not mere administrative approval of transactions.
- Valuation Error – The Sandiganbayan’s assumption that the assessor’s ₱5/m² figure reflected true market value was unfounded. In negotiated purchases, parties may lawfully fix price by mutual agreement, taking into account location, potential, and other factors. No proof established that ₱80/m² exceeded fair value in 1978.
- Auditorial Function – An auditor cannot be charged with conspiracy merely for affixing a final signature amid voluminous documents. Reasonable reliance on subordinates and fair delegation is permissible absent indicators of fraud.
Dissenting Opinion
Justice Grino-Aquino, joined by four colleagues, would affi
Case Syllabus (G.R. No. 81563)
Case Citation
- 259 Phil. 794, En Banc
- G.R. Nos. 81563 and 82512
- Date of Decision: December 19, 1989
- Majority Opinion by Justice Gutierrez, Jr.
- Dissenting Opinion by Justice Carolina C. Grino-Aquino
Parties
- Petitioners:
• Amado C. Arias – Auditor, Rizal Engineering District, Pasig
• Cresencio D. Data – District Engineer, Pasig Engineering District - Respondent:
• The Sandiganbayan
Facts
- The Bureau of Public Works undertook the Mangahan Floodway Project (Marikina–Pasig flood control).
- Acquisition was by negotiated purchase of 19,004 sq m in Rosario, Pasig.
- Original tax declarations (1973/1978) classified the land as “riceland” at P5.00/sq m; the deed of sale (1978) portrayed it as “residential” at P80.00/sq m.
- Supporting papers—tax declarations, certifications, sworn statements—were falsified or forged.
- A General Voucher (No. 85-2-7809-52) for P1,520,320.00 was prepared, certified by district officials, pre-audited by Arias, and paid by PNB checks.
- Arias retained all supporting documents in his custody until June 1982.
- A later investigation uncovered the document falsifications and pricing discrepancies.
Procedural History
- Sandiganbayan convicted six accused, including Arias and Data, under Section 3(e) of R.A. 3019 for causing undue injury to the Government.
- Sentences: imprisonment (3–6 years), perpetual disqualification, joint indemnity of P1,425,300.00, and costs.
- Petitioners filed separate petitions in the Supreme Court.
- The Solicitor General filed a consolidated manifestation recommending acquittal for Arias and Data.
Issues
- Whether the prosecution proved beyond reasonable doubt that Arias and Da