Case Summary (G.R. No. 233152)
Background of the Case
The case revolves around allegations that Coloma, during his tenure as Deputy Director of the Philippine National Training Institute (PNTI), committed acts of graft and corruption by facilitating the unjust purchase of land for training facilities. The Ombudsman found probable cause against Coloma for three counts of violating Section 3(e) of R.A. 3019.
Charges and Prosecution's Position
The Amended Information accuses Coloma of causing undue injury to the Philippine Public Safety College (PPSC) by purchasing a 10,000 square meter property from contractor Engr. Rolando Lim and his wife Albia J. Lim. The purchase, valued at ₱1,500,000, lacked proper authorization, competitive bidding, and documentation confirming ownership. Allegations included Coloma's failure to consider available government property for the project and that the purchase price was grossly inflated compared to prevailing market rates.
Defense Arguments
Coloma contended that he acted under the direction of PPSC leadership and insisted that all necessary procedures were followed. He argued that funds were allocated for the project, and his reporting did not indicate foul play. The defense maintained that the property acquisition was duly approved, and all actions were in line with administrative protocols.
Sandiganbayan Ruling
The Sandiganbayan found Coloma guilty of violating Section 3(e) of R.A. 3019 on the grounds that he acted with manifest partiality and evident bad faith. The court established that Coloma's actions directly resulted in financial disadvantage to the government while favoring a private contractor. He was sentenced to a prison term of six years and one month to ten years, along with perpetual disqualification from holding public office.
Legal Findings and Elements of Graft
The ruling clarified that the elements constituting graft—a public officer's manifest partiality and evident bad faith resulting in undue injury—were present in Coloma's conduct. The Sandiganbayan highlighted that Coloma knowingly inflated the property’s value and facilitated payments to contractors under the guise of legitimate financial management.
Appellate Review
Coloma's subsequent appeal emphasized that only questions of law could be raised from the Sandiganbayan's findings. The Supre
...continue readingCase Syllabus (G.R. No. 233152)
Case Overview
- The case involves Dionisio B. Coloma, Jr., a Police Chief Superintendent, who was charged with three counts of violating Section 3(e) of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019).
- The specific count addressed in this petition pertains to the unauthorized purchase of land for a training school facility in Bongao, Tawi-Tawi.
- The allegations stem from actions taken between June 2001 and October 2001, during his tenure as Deputy Director of the Philippine National Training Institute (PNTI).
Charges Against Coloma
- The Amended Information filed against Coloma alleges that he committed the offense with grave abuse of authority, giving unwarranted benefits to private contractors Engr. Rolando Lim Yankee Espaldon and his wife, Albia J. Lim.
- Key points of the transaction included:
- Purchase of a 10,000 square meter property at P1,500,000.00 without prior authority or public bidding.
- Lack of documentation proving ownership of the property by the Lim spouses.
- Failure to consider alternative properties that had been allocated to PPSC for free.
Prosecution's Version
- The prosecution presented evidence of a Special Allotment Release Order (SARO) from the Department of Budget and Management (DBM) for various training facilities, including the Regional Training School (RTS-9) in Tawi-Tawi.
- The prosecution argued that Coloma orch