Case Summary (G.R. No. 207154)
Petitioners and Respondents
• Office of the Ombudsman (OMB) vs. Venancio G. Santidad (G.R. No. 207154) – Administrative case for Serious Dishonesty and Gross Neglect of Duty
• Venancio G. Santidad vs. People of the Philippines (G.R. No. 222046) – Criminal case for Falsification of Public Documents
Key Dates
• December 2–4, 2002 / January–April 2003 – Procurement, bidding, issuance of sales invoice, inspection, and preparation of Invoice Receipts for Property (IRPs) for 21 Mitsubishi Delica vans
• February 2, 2007 – NBI affidavit-complaint filed with the Office of the Ombudsman
• July 13, 2010 – OMB decision finding Santidad guilty of Serious Dishonesty
• May 29, 2012 – Court of Appeals decision reversing the OMB’s finding
• September 24, 2015 – Sandiganbayan conviction for Reckless Imprudence resulting in Falsification of Public Documents
• December 5, 2019 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution – Public officers as stewards of public trust (Art. XI, Sec. 1)
• Revised Penal Code, Article 171(4) – Falsification of Public Documents by making untruthful statements in a narration of facts
• Revised Penal Code, Article 365 – Reckless Imprudence resulting in damage to public documents
• Republic Act No. 3019 – Anti-graft and corrupt practices
• Uniform Rules on Administrative Cases in the Civil Service, Rule IV, Sec. 52(a) – Administrative offenses of Serious Dishonesty and Gross Neglect of Duty
Factual Background
Congressman Abaya secured ₱10 million for a multi-cab project; DOTC allocated ₱7.72 million for procurement. Santidad, as PSPMS Director, certified requisition and approved Purchase Order No. DOTC-2003-03-70 for 21 Mitsubishi Delica vans at ₱360,000 each. Super Car Center issued an unsigned sales invoice. DOTC officers Cruz and Desiderio allegedly inspected and accepted the vans in Bulacan on April 1, 2003. Santidad signed 21 IRPs certifying transfer to barangay recipients in Isabela, who purportedly signed receipts. Payments totaling ₱7.216 million were released. Subsequent COA and NBI investigations revealed none of the beneficiaries received the vans; some vans were sold to third parties, others unregistered or remained with the original dealer.
Administrative Proceedings
An administrative complaint for Dishonesty and Gross Neglect of Duty was filed. The OMB found Santidad guilty of Serious Dishonesty, imposing dismissal, cancellation of eligibility, forfeiture of benefits, and disqualification. Santidad’s motion for reconsideration was denied. The Court of Appeals, however, exonerated him, ruling that he relied in good faith on supporting documents and beneficiary signatures, with no red flags indicating irregularity. The Supreme Court reviewed these conflicting findings.
Criminal Proceedings
Santidad was indicted before the Sandiganbayan for 21 counts of Falsification of Public Documents under Article 171(4) RPC. After trial, the anti-graft court convicted him instead of falsification, for Reckless Imprudence resulting in Falsification of Public Documents under Article 365 RPC, sentencing him to arresto mayor to prisión correccional and ordering civil indemnity. His motion for reconsideration was denied.
Issues Presented
- Whether Santidad’s signature on the IRPs in good faith precludes administrative liability for Serious Dishonesty or Gross Neglect of Duty.
- Whether the prosecution proved beyond reasonable doubt his criminal liability for Falsification of Public Documents or Reckless Imprudence.
- Applicability of the presumption of regularity in official acts (Arias doctrine).
Court’s Analysis on Administrative Liability
The Supreme Court found multiple “red flags” that should have alerted Santidad:
- The Certificate of Acceptance lacked required plate numbers, LTO registrations, and insurance details, contrary to PO conditions.
- The Inspection Report conflated references to the original 18-unit requisition, ignoring the additional three vans.
- Disbursement vouchers and released checks totaled ₱7.216 million, below the ₱7.56 million contract price and ₱7.72 million authorized budget.
- Budget realignment for undeliverable trucks required fresh documentation and risked bidder disqualification.
- Only two of 21 IRPs bore receipt dates, both predating the alleged April 1 inspection, and two IRPs lacked beneficiary signatures.
These anomalies imposed a duty on Santidad—who played a central role in every procurement stage—to conduct further inquiries rather than blindly rely on subordinates. The Court invoked the 1987 Constitution’s public-trust doctrine, requiring heightened diligence from high-ranking officers. It distinguished Arias v. Sandiganbayan,
Case Syllabus (G.R. No. 207154)
Procedural History
- Two petitions for review on certiorari were consolidated before the Supreme Court:
• G.R. No. 207154 filed by the Office of the Ombudsman to challenge the May 29, 2012 Decision and April 29, 2013 Resolution of the Court of Appeals in CA-G.R. SP No. 119936
• G.R. No. 222046 filed by Venancio G. Santidad to challenge the September 24, 2015 Decision and November 25, 2015 Resolution of the Sandiganbayan in Criminal Case Nos. SB-10-CRM-0261 to SB-10-CRM-0281 - The Ombudsman’s administrative case (OMB-L-A-07-0166-B) resulted in a finding of Serious Dishonesty against Santidad, penalizing him with dismissal and accessory penalties.
- Santidad was criminally indicted before the Sandiganbayan for 21 counts of falsification of public documents under Article 171, paragraph 4 of the Revised Penal Code; the anti-graft court convicted him of reckless imprudence resulting in falsification.
- Both parties sought relief by certiorari under Rule 45 of the Rules of Court, raising questions of law and fact concerning administrative liability and criminal culpability.
Facts
- Late Congressman Antonio M. Abaya requested P10 million from the Office of the President for multi-cab vehicles for 235 barangays in Isabela; P8 million was approved.
- DOTC, through its Procurement, Supplies and Property Management Service (PSPMS) headed by Santidad, handled procurement.
- Initial plan: one Mitsubishi L-200, one Nissan Pathfinder, and several Mitsubishi Delica vans; P7,720,000.00 was allocated by ALOBS No. LF(CO)02-12-00478 and RIV No. H-413-2002.
- Bids were opened; Super Car Center won for 18 Delica vans; after two pick-up trucks became unavailable, funds were realigned to acquire three additional Delica vans.
- PO No. DOTC-2003-03-70 was issued for 21 Delica vans at P360,000.00 each (total P7,560,000.00); Santidad signed the recommending approval.
- Super Car Center issued an unsigned Sales Invoice No. 0026 (March 28, 2003); DOTC issued a Certificate of Acceptance (March 28, 2003) and an Inspection Report (April 1, 2003).
- Twenty-one IRPs were prepared by the Property Utilization and Disposal Division; Santidad signed each “Invoice” portion certifying transfer to the beneficiaries; recipients signed “Receipt” portions.
- Payments totalling P7,216,363.63 were released by Land Bank Checks Nos. 41232 and 31883.
- COA and NBI investigations revealed that none of the named recipients actually received the vans; some were sold to third parties, others were unregistered or still under Microvan, Inc.