Case Summary (G.R. No. 197204)
Case Background
The case involves a petition for review on certiorari challenging the Decision and subsequent Resolutions of the Sandiganbayan concerning Criminal Case No. 20574. This criminal case revolved around allegations of malversation, through the falsification of public documents, against several public officers in connection with the procurement of combat clothing and individual equipment (CCIE) for the Philippine National Police (PNP). The primary issue centered on the release of two Advices of Sub-Allotment (ASA) totaling PHP 20 million, supposedly for the purchase of CCIE items, which were later found to be linked to fictitious payrolls and personnel.
The Facts
During the third quarter of 1992, the PNP's Directorate for Comptrollership issued two ASAs amounting to PHP 20 million for the procurement of CCIE items for CRECOM. The ASAs were signed by authorized officials, allowing the funds to be disbursed based on disbursement vouchers prepared by Garcia and approved varying by Brizuela, who was the disbursing officer. The lack of actual delivery of CCIE items became apparent when a post-audit by the Commission on Audit uncovered that the documented personnel receiving the benefits were fabricated. An investigation led to the summarization of sworn statements from various officials confirming the absence of the purchased items and the falsification of payroll registers.
Criminal Proceedings
Following the investigation, the Office of the Ombudsman filed charges against several officers involved, including Garcia and Brizuela, for causing undue injury to the government by approving payments for non-existent items. The Sandiganbayan found the evidence of negative intent, as the accused had turned over the entire PHP 20 million after funds were disbursed and facilitated the issuance of checks that were eventually deposited into unauthorized accounts.
Court Findings
The Sandiganbayan convicted Garcia, Brizuela, and Luna for violations of the Anti-Graft and Corrupt Practices Act under Section 3(e) of Republic Act No. 3019. The court determined that the petitioners acted with evident bad faith by approving transaction documents without the appropriate verification of legitimacy. It underscored the essential elements of the offense: the status of the accused as public officers, their actions characterized by manifest partiality or evident bad faith, and the resulting injury to the government.
Appeal and Rulings
Garcia and Brizuela's defenses relied on a presumption of regularity in their official functions; however, the court ruled that they had failed to demo
...continue readingCase Syllabus (G.R. No. 197204)
Case Background
- Case Reference: G.R. No. 197204
- Date of Decision: March 26, 2014
- Court: Supreme Court of the Philippines, Second Division
- Petitioners: Danilo O. Garcia and Joven SD. Brizuela
- Respondents: Sandiganbayan and People of the Philippines
- Nature of the Case: Petition for review on certiorari against the Sandiganbayan's decision and resolutions in Criminal Case No. 20574.
Facts of the Case
- The Philippine National Police (PNP) issued two Advice of Sub-Allotments (ASAs) totaling PHP 20,000,000 for the procurement of combat clothing and individual equipment (CCIE) for the Cordillera Regional Command (CRECOM).
- The ASAs were signed by Guillermo T. Domondon, with the authority delegated to P/Supt. Van D. Luspo.
- Petitioner Danilo O. Garcia, as Assistant Regional Director for Comptrollership, directed the preparation of disbursement vouchers totaling PHP 20,000,000, which were signed by him or C/Supt. Armand D. Agbayani.
- Joven SD. Brizuela, as Disbursing Officer, was the sole payee for the cash advances.
- The checks issued were encashed by Brizuela, who then turned over the funds to Garcia in the presence of Juan G. Luna, the Finance Officer.
- Subsequent audits revealed irregularities, including forged signatures and fictitious personnel payrolls, leading to an investigation by the PNP and ultimately, criminal charges against the involved officers.
Procedural History
- Following the investigation, the Office of the Ombudsman filed an Amended Information against the accused for malversation through falsification of public documents and violations of the Anti-Graft and Corrupt