Case Summary (G.R. No. 161083)
Facts of the Case
On August 3, 1992, Edgard Sta. Maria received a cash advance of P33,190.73 from the Morong Water District for a pipeline extension project. He submitted a partial liquidation of P15,000.00, alleging it was used for related expenses, supported by a reimbursement receipt from Engineer Ricardo Reyes. Subsequently, he reported a total liquidation of P16,790.40 for further project costs, which was authorized by the Board of Directors. Following his ousting on December 14, 1992, a complaint was filed against Sta. Maria and Censon for violations of the Anti-Graft and Corrupt Practices Act and malversation of public funds.
Proceedings Before the Ombudsman
The complaint alleged that Sta. Maria and Censon misappropriated funds intended for the project, claiming that no actual design work was performed and asserting that the money was instead pocketed. In their counter-affidavits, both respondents denied the allegations, with Sta. Maria claiming retaliatory motives behind the complaint. On March 28, 1994, the Ombudsman dismissed the complaint, citing insufficient evidence for probable cause on the alleged violations.
Ombudsman’s Resolution and Motion for Reconsideration
On May 27, 1994, the Ombudsman affirmed its dismissal of the motion for reconsideration, highlighting that the evidence presented supported the respondents’ actions in liquidating the funds. It emphasized that the diversion of funds had been authorized and concluded that there was no conspiracy or misappropriation as claimed by the petitioner.
Issues Raised in the Petition for Certiorari
The petitioner subsequently filed a petition for certiorari, alleging that the Ombudsman had acted with grave abuse of discretion in dismissing the complaint. The petitioner argued that the decision disregarded evidence that would establish a prima facie case of malversation.
Legal Standards and Findings
The Supreme Court highlighted that its review of the Ombudsman’s findings is limited to issues of law, as per Republic Act No. 6770. The Court underscored that the Ombudsman’s factual findings, when supported by substantial evidence, are conclusive. It noted that the evidence indicated
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Case Background
- The case originated from a petition for certiorari filed by Morong Water District against the Office of the Deputy Ombudsman and private respondents for the dismissal of a complaint for violation of R.A. 3019 (Anti-Graft and Corrupt Practices Act) and Article 217 of the Revised Penal Code.
- The complaint was filed against Edgard Sta. Maria and Emma Censon, who were the former General Manager and advisor of the Morong Water District, respectively.
- The Ombudsman’s Resolution dated March 28, 1994, dismissed the case due to insufficient evidence to establish probable cause for malversation or violation of the Anti-Graft law.
- An Order dated May 27, 1994, denying the motion for reconsideration was also contested.
Parties Involved
- Petitioner: Morong Water District
- Respondents:
- Edgard Sta. Maria (former General Manager)
- Emma Censon (Local Water Utilities Administration advisor)
- Wilfred L. Pascasio, Raul R. Arnau, Abelardo L. Aportadera, Jr., and Francisco Villa (Ombudsman officials involved in the case)
Factual Background
- On August 3, 1992, Edgard Sta. Maria received a cash advance of ₱33,190.73 for the design and execution of the Wawa pipeline extension project.
- Sta. Maria provided partial liquidation of ₱15,000.00, claiming it was paid to Engineer Ricardo Reyes for design work, which was supported by a reimbursement receipt.
- Sta. Maria later liquidated an additional ₱16,790.40 for another pipeline extension, authorized by the Board of