Case Summary (G.R. No. 158014)
Case Background
Manlangit was accused of violating Article 218 of the Revised Penal Code after failing to properly account for a public fund of P176,300 received for the Commission's activities. The complaint was filed by Artaserxes L. Sampang, the Executive Director of the Commission, citing that Manlangit had not rendered a true account of the funds entrusted to him. Manlangit, upon his resignation, did not provide the necessary liquidation report, which led to his indictment.
Legal Framework
Article 218 of the Revised Penal Code outlines the obligations of public officers to render accounts for public funds entrusted to them, with criminal liability arising from the failure to do so after a specified period. The case references the implications of COA Circular No. 90-331, which mandates timely accounting of cash advances, and highlights that no demand for such accounting is explicitly stated as a prerequisite for liability under Article 218.
Procedural Posture
After the Ombudsman filed charges, Manlangit submitted a counter-affidavit claiming he did not intend to appropriate the funds and cited reasons for the delay in reporting. Despite this, the Sandiganbayan found that the evidence of non-compliance with the accounting requirement was compelling, thus leading to a conviction for violating Article 218.
Key Legal Issues
Manlangit raised several key legal issues on appeal, including whether prior demand from the Commission on Audit (COA) was necessary to secure a conviction under Article 218, the applicability of the ruling in United States v. Saberon, and whether the case was rendered moot by the submission of his liquidation report.
Court's Analysis
The Sandiganbayan and, subsequently, the appellate court noted that the elements of Article 218 do not require prior demand for accountability as a prerequisite for liability. The essential requirement under Article 218 is that the public officer must be legally mandated to render accounts and fail to do so. The court further emphasized that the timely submission of the liquidation report was breached, with Manlangit’s report presented after the statutory deadline.
Application of the Law
The court analyzed the implications of the COA Circular and clarified that the standards set forth do indeed provide timelines for submission without necessitating a prior demand. As articulated in the decision, the absence of demand does not negate the liability under the statute, as it unequivocally expresses the public off
...continue readingCase Syllabus (G.R. No. 158014)
Case Background
- This case involves a petition for review filed by Rosulo Lopez Manlangit against the Honorable Sandiganbayan and the People of the Philippines.
- The action seeks to overturn the Decision dated February 27, 2003, and the Resolution dated April 24, 2003, relating to Criminal Case No. 26524.
- Manlangit was convicted for violating Article 218 of the Revised Penal Code, specifically for failing to render an account of public funds.
Antecedent Facts
- On October 16, 1998, Manlangit, serving as Officer-in-Charge for Information, Education, and Communication of the Pinatubo Commission, received P176,300 for the Commission’s 6th Founding Anniversary Info-Media Activities.
- He resigned a few months later without accounting for the received funds.
- On April 12, 2000, Artaserxes L. Sampang, Executive Director of the Commission, filed an affidavit-complaint against him, citing violations of Articles 217 and 218.
- Sampang referenced COA Circular No. 90-331, which mandated public officers to render a true account of public funds entrusted to them.
Petitioner's Defense
- Manlangit submitted a counter-affidavit claiming no intention of misappropriating funds and cited several reasons for the delay in submitting the liquidation report:
- Organizational confusion due to a management change.
- His resignation and subsequent job search.
- Personal and family issues.
- He asserted that he submitted the required liquidation report on July 12, 2000, but Virginia C. Yap, the Deputy Executive Director, contradicted this claim, stating no report had been submitted.
Legal Proceedings
- The Office of the Deputy Ombudsman file