Case Summary (G.R. No. 168951)
Timeline of Key Events
- September 19, 1994: Dr. Posadas forms a Task Force on Science and Technology Assessment, Management and Policy.
- June 6, 1995: UP establishes the UP Technology Management Center based on the Task Force's proposal.
- November 7, 1995: Dr. Dayco, as Officer-in-Charge, appoints Dr. Posadas as Project Director of the TMC Project.
- August 22, 1996: The Commission on Audit (COA) suspends payments to UP TMC personnel, including Dr. Posadas.
- June 28, 2005: Sandiganbayan finds both petitioners guilty of crimes under Republic Act 3019 and Republic Act 6713.
Applicable Law
The relevant laws involve Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act, and Republic Act No. 6713, the Code of Conduct and Ethical Standards for Public Officials and Employees.
Proceedings and Rulings
On July 17, 2013, the Court affirmed the Sandiganbayan's decisions against the petitioners. Following their motions for reconsideration, the Court reassessed the case.
Good Faith in Appointments
The Court examined whether Dr. Dayco acted in good faith when appointing Dr. Posadas in his role as Project Director and consultant. The Court found that allegations of bad faith were unsubstantiated, arguing that the concept of bad faith in this context must reflect a conscious wrongdoing. The decisions were indicative of a lack of legal knowledge rather than deceit.
Qualifications and Integrity of Appointments
The prosecution failed to demonstrate that Dr. Dayco exhibited manifest partiality in choosing Dr. Posadas for the positions. The Court noted that Dr. Posadas was the most qualified for the role, given his prior involvement and expertise. Moreover, the overwhelming support from peers in the Task Force reiterated the appropriateness of the appointments.
Nature of the Misstep
The Court characterized the actions of Dr. Dayco and Dr. Posadas as administrative missteps rather than criminal acts. Evidence showed that appointments in academia are often treated with leniency regarding compensation for additional duties. Furthermore, there was no clear prohibition against such additional compensation for university officials.
Impact of Prior Investigations
The context of the case was clouded by rivalry and previous administrative investigations initiated by Dr. Posadas against colleagues, which could have biased the prosecutorial view. The elements of personal animosity appeared to play a role in escalating what was essentially an administrative issue.
Absence of Unwarranted Benefit
The prosecution failed to establish that either Dr. Posadas or Dr. Dayco caused undue i
...continue readingCase Syllabus (G.R. No. 168951)
Case Overview
- The case pertains to the separate Motions for Reconsideration filed by petitioners Dr. Roger R. Posadas and Dr. Rolando P. Dayco against the Sandiganbayan’s decision dated July 17, 2013.
- The primary legal issues involve allegations of grave misconduct and abuse of authority related to appointments made during their tenure at the University of the Philippines (UP) Diliman.
Background Facts
- Dr. Posadas was the Chancellor of UP Diliman who initiated the formation of a Task Force on Science and Technology Assessment, Management, and Policy on September 19, 1994.
- The Task Force proposed curricula for master's and doctoral programs related to technology management, leading to the establishment of the UP Technology Management Center (UP TMC) on June 6, 1995.
- Dr. Posadas declined the nomination for Director of UP TMC, resulting in Professor Jose B. Tabbada being designated as the acting director.
- Subsequently, Dr. Posadas secured funding for the TMC Project from the Canadian International Development Agency.
- On October 5, 1995, Malacañang authorized Dr. Posadas and UP officials to attend a foundation day in Fujian, China. Before his departure, he designated Dr. Dayco as Officer-in-Charge (OIC).
- Dr. Dayco appointed Dr. Posadas as Project Director and consultant for the TMC Project on November 7, 1995, retroactive to September 18, 1995.
- The Commission on Audit (COA) later issued a notice of suspension regarding payments made to UP TMC