Case Summary (G.R. No. 246942)
Background of the Case
The case arose from an Information filed against the accused-appellants and two other individuals, Robert P. Balao and Jose M. Cruz, in connection with the Pahanocoy Sites and Services Project in Bacolod City, Negros Occidental. The allegations indicated that, during their respective tenures as public officers of the National Housing Authority (NHA), they conspired to authorize excessive payments to a private construction company, Triad Construction and Development Corporation, for work that was not completed or justified.
Details of the Irregularities
The project was initially awarded to A.C. Cruz Construction but was rescinded due to delays. Subsequently, the contract was transferred to Triad at a higher cost. A subsequent Special Audit by the Commission on Audit (COA) revealed that payments made to Triad far exceeded the allowable limits set by COA regulations, with the accused failing to obtain necessary approvals before making excess payments. The COA identified duplicities in the documentation submitted for payment, revealing a pattern of misconduct among the accused.
Court Proceedings and Rulings
The Sandiganbayan found the accused-appellants guilty of causing undue injury to the government and providing unwarranted benefits to the private contractor. It deemed that the accused exhibited manifest partiality and evident bad faith by facilitating unauthorized payments and failing to adhere to proper bidding processes and contract variation orders.
Appeal and Final Decision
Dissatisfied with the decision, the accused-appellants filed for reconsideration, which was denied. They subsequently appealed to the Supreme Court, which affirmed the Sandiganbayan’s ruling against Angsico, Dacalos, Lobrido, and Espinosa, finding their actions to constitute a clear violation of the law. However, the Court acquitted Lazarte due to insufficient evidence linking him to the wrongdoing.
Legal Standards and Analysis
The Supreme Court highlighted the elements necessary to establish the offense under Section 3(e) of Republic Act No. 3019, namely: the stat
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Consolidated Appeals
- The case involves consolidated ordinary appeals filed by accused-appellants Josephine Casenas-Hottle (formerly Angsico), Virgilio V. Dacalos, Felicisimo F. Lazarte, Jr., Noel A. Lobrido, and Josephine T. Espinosa.
- They are appealing against the Decision dated December 7, 2018, and the Resolution dated March 28, 2019, of the Sandiganbayan, which found them guilty of violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
Background of the Case
- The case originated from an Information filed against the accused-appellants and two other individuals, Robert P. Balao and Jose M. Cruz, for the alleged crime.
- The charge stated that the accused, as public officials of the National Housing Authority (NHA), unlawfully caused the payment of public funds amounting to PHP 1,280,964.20 to Triad Construction and Development Corporation, despite the actual work accomplished being valued at only PHP 330,075.76.
Facts Surrounding the Pahanocoy Project
- In 1990, the NHA awarded a contract for the Pahanocoy Sites and Services Project to A.C. Cruz Construction, which was later rescinded due to delays.
- The unfinished portion of the project was subsequently awarded to Triad Construction at a higher contract price.
- Following the completion of the project, several irregularities were reported by the NHA's project engineer, prompting a Special Audit by the Commission on Audit (COA).
Findings of the COA Audit
- The COA's Special Audit revealed that the payment made to Triad