Case Summary (G.R. No. 205561)
Background of the Case
Dionisio B. Coloma, Jr. served as the Director of the Philippine National Police Academy (PNPA) and was designated as Special Assistant to the Logistics and Installation Services (LIS) of the Philippine Public Safety College (PPSC) in 1999. His primary involvement was to oversee the construction of the Philippine National Police Regional Training Site 9 (RTS 9) in Bongao, Tawi-Tawi. The site selection process culminated in a choice of land owned by Juaini Bahad, which was sold to the late Albia Lim, spouse of Engineer Rolando E. Lim. Coloma, together with PPSC administrators, initiated construction facilitated by public funds.
Allegations and Charges
Coloma was charged with violating Section 3(e) of R.A. 3019, alleging that he caused undue injury to the PPSC by misrepresenting the completion and cost of the RTS 9 project. It was claimed that Coloma's reports of the project's status were significantly inflated and misleading, specifically stating that construction was more advanced than reality reflected.
Findings of the Investigation
An inquiry led by SPO4 Gilbert Concepcion revealed numerous discrepancies in Coloma's reports. An ocular inspection indicated that:
- The land development was inaccurately reported as completed.
- Only certain structures such as the administration building and a classroom existed, while the promised fifty-capacity barracks was absent.
- The value of constructed facilities was over-reported leading to an alleged injury to public funds amounting to approximately P2,500,000.
Trial and Evidence Presented
During the trial, witnesses testified about the status and financial management of RTS 9. The prosecution's case was founded on eyewitness accounts and fiscal documentation which discredited Coloma's claims of successful project management. Coloma, testifying in his defense, contended that he acted per institutional directives and denied any misrepresentation intentions.
Decision of the Sandiganbayan
On May 17, 2012, the Sandiganbayan found Coloma guilty, concluding that he acted in evident bad faith, exhibited manifest partiality, and gross negligence, which led to undue government injury. He was sentenced to imprisonment and barred from holding public office. The Sandiganbayan rigorously analyzed both testimonial and documentary evidence, ruling that Coloma failed to accurately report the project's progression and financial transactions.
Coloma's Appeal and Contentions
Coloma contested the Sandiganbayan's findings, arguing that key testimony lacked concrete value and that he simply reported based on observable facts at the time. He also claimed that the absence of a Notice of Disallowance from the Commission on Audit further weakened the pr
...continue readingCase Syllabus (G.R. No. 205561)
Case Background
- Jurisdiction: Second Division of the Supreme Court of the Philippines.
- Decision Date: September 24, 2014.
- Case No: G.R. No. 205561.
- Petitioner: P/C Supt. Dionisio B. Coloma, Jr.
- Respondents: Hon. Sandiganbayan (Third Division) and People of the Philippines.
- Key Legislation: Republic Act (R.A.) No. 3019, also known as the Anti-Graft and Corrupt Practices Act.
Procedural History
- The petition for review on certiorari was filed under Rule 45 of the Rules of Court.
- The case concerned the May 17, 2012 Decision and the January 11, 2013 Resolution of the Sandiganbayan, which found Coloma guilty of violating Section 3(e) of R.A. No. 3019.
Facts of the Case
- Coloma served as the Director of the Philippine National Police Academy (PNPA) and later as Special Assistant to the Director of the Logistics and Installation Services (LIS) at the Philippine Public Safety College (PPSC).
- In 1999, he assisted in the acquisition of land for the construction of the Philippine National Police Regional Training Site 9 Annex (RTS 9) in Bongao, Tawi-Tawi.
- The land was previously owned by Juaini Bahad and later sold to Albia Lim, wife of a labor contractor.
- After site inspections in 2002, a graphical layout plan for the construction, which included barracks and classrooms, was approved.
- Funding for the project came from the Congressional Development Fund of Representative Nur Jaafar.
- The total cost for the project was approximately P5,