Case Summary (G.R. No. 210603)
Facts of the Case
The petitioners, alongside Dalman, were charged with a violation of Section 23 of Presidential Decree No. 1752, amended by Republic Act No. 7742. They were accused of not remitting a total of ₱23,784.39, which included employee contributions for the HDMF, thereby causing financial prejudice to their fellow employees. The prosecution established that appropriate salary deductions were made, but remittances were not completed, triggering complaints from affected employees.
Prosecution's Case
The prosecution focused on the testimony and documents demonstrating that the hospital still operated under normal circumstances despite administrative changes. According to the prosecution, the payroll was prepared, deductions were noted, but the money was not remitted after the hospital underwent devolution to the provincial government.
Defense Arguments
The defense argued based on several points: Grado asserted that she ceased to issue checks for HDMF contributions due to the devolution under the Local Government Code, believing it was now the provincial government's responsibility. Saguin supported this, claiming her functions had also shifted. Dalman reiterated their position, indicating an awareness of the administrative transfer but lacked authority to address remittances.
Rulings of Lower Courts
Municipal Trial Court in Cities (MTCC): On May 14, 2009, the MTCC found all accused guilty beyond reasonable doubt and imposed fines and restitution.
Regional Trial Court (RTC): The RTC affirmed the MTCC's ruling, denying that devolution exempted the accused from their obligations. It highlighted that the act of non-remittance constituted a violation irrespective of intent.
Sandiganbayan: This court upheld the previous rulings, reinforcing the accusations of failure to remit and dismissing claims that devolution altered responsibility.
Issue on Discretion of the Sandiganbayan
The issue presented in the Supreme Court involved whether the Sandiganbayan erred in affirming the lower courts' decisions amidst arguments questioning the application of penal sanctions against the petitioners, who contended they were ordinary employees and not responsible under the statute in question.
Supreme Court's Ruling
The Supreme Court oriented its ruling around the principle that it typically does not engage in factual reevaluation under Rule 45. However, it identified that this case fell within exceptions due to misapprehension of facts leading to erroneous conclusions regarding criminal liability.
The Court emphasized that the petitioners' failure to remit the HDMF amounts was with lawful cause due to the devolution
...continue readingCase Syllabus (G.R. No. 210603)
Case Citation
- G.R. No. 210603
- Date of Decision: November 25, 2015
- Reported in: 773 Phil. 614
Background of the Case
- Petitioners Editha B. Saguin and Lani D. Grado, along with Ruby C. Dalman, were charged with violating Section 23 of Presidential Decree No. 1752, as amended by Republic Act No. 7742.
- The case originated from a complaint filed on December 4, 1997, related to their duties at the Rizal Memorial District Hospital (RMDH) in Dapitan City.
- The charges stemmed from the failure to remit deductions from employee salaries for the Home Development Mutual Fund (HDMF) contributions and loan repayments for March 1993, amounting to a total of P23,784.39.
Proceedings and Decisions
Municipal Trial Court in Cities (MTCC):
- On May 14, 2009, the MTCC found all three accused guilty and imposed a fine of P50,000 each, with subsidiary imprisonment for failure to pay.
- Ordered to pay the total remittance owed plus interest.
Regional Trial Court (RTC):
- The RTC affirmed the MTCC ruling on November 10, 2009, while modifying the sentence, emphasizing that the devolution of the hospital to the provincial government did not absolve the accused from their responsibilities.
Sandiganbayan:
- In its April 4, 2013 decision, the Sandiganbayan upheld the conviction