Case Summary (G.R. No. 109991)
Summary of Allegations
The information against the accused stated that on or around February 16, 1988, in Palapag, using evident bad faith and manifest partiality, Quibal and Deniega conspired with Guevarra to cause undue injury to the government by paying P650,000 for market construction that only cost P301,746.65, thereby giving unwarranted benefits to Guevarra and causing a financial loss of P348,345.35 to the municipality.
Contract Details and Payments Made
On November 27, 1987, the municipality contracted Floters Construction Company, represented by Guevarra, for a total project price of P652,562.60 to be completed within 100 days. Between February 16 and April 22, 1988, Quibal and Deniega issued four checks totaling P650,000. However, by June 1988, the contractor had abandoned the project, with an inspection by the Commission on Audit (COA) revealing only 36.24% of the project completed.
Audit Findings and Irregularities
A COA audit discovered significant irregularities, including incomplete work and unsigned payment vouchers. The audit team found that payments were made without adhering to acceptable disbursement practices, failing to attach necessary supporting documents and certificates of acceptance as mandated by law when payments exceeded certain thresholds.
Defense of Petitioners
During trial, Deniega acknowledged disbursing P650,000 but claimed he had submitted proper documentation, implying that the vouchers presented by the prosecution were not the actual ones used. Quibal justified the early payments as necessary to secure construction materials amidst fluctuating prices, asserting the value of unused materials should offset the payments made.
Sandiganbayan's Findings
The Sandiganbayan found the petitioners guilty of violating Section 3(e) of R.A. 3019, emphasizing that they acted with manifest partiality and bad faith. They did not adhere to the contractual obligation to pay based on the percentage of work completed. The court noted that negligence was evident in their failure to enforce a penalty clause, resulting in both undue payments and damages to the municipal government.
Legal Implications and Rulings
The Supreme Court affirmed the guilty verdict, reinforcing that the criteria for imposing liability under the Anti-Graft and Corrupt Practices Act were met. The court held that the petitioners demonstrated gross negligence and did not provide adequate justification for their actions, which led to significant financial losses for the municipality.
Denial of Due Proc
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Case Overview
- Petitioners Elias C. Quibal and Antonio U. Deniega were charged with violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
- The charges stemmed from their roles as the Mayor and Municipal Treasurer of Palapag, Northern Samar, concerning payments made to a contractor for the construction of a municipal public market.
- The contractor, Eduardo C. Guevarra, was also implicated but remains at large.
Background of the Case
- A contract was executed on November 27, 1987, between the municipality of Palapag and Floters Construction, represented by Guevarra, for the construction of a public market at a price of P652,562.60 with a completion period of 100 days.
- Between February 16, 1988, and April 22, 1988, the petitioners authorized payments totaling P650,000.00 to the contractor.
- Despite these payments, the contractor abandoned the project by June 1988.
- A COA Special Audit in August 1988 revealed that only 36.24% of the construction was completed, with the actual cost of completed work at P301,746.65.
Findings and Irregularities
- The audit discovered that the payments were made without proper documentation; vouchers were unsigned, and no Certificate of Acceptance was issued for significant payments.
- The investigation led to recommendations for legal action against the petiti