Domingo De Guzman v. The Sandiganbayan (second Division)
REITERATIONFacts
The Antecedents: Domingo de Guzman, then Officer-in-Charge and Assistant Director of the Bureau of Plant Industry, received P200,000.00 for official training programs. He later claimed credit for this amount in a disbursement voucher but failed or refused to produce supporting receipts when required. This failure led to his prosecution for violation of Section 3(e) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act, which penalizes public officers for causing undue injury to the government or giving unwarranted benefits through manifest partiality, evident bad faith, or gross inexcusable negligence. Procedural History: The case originated with the filing of an information against petitioner Domingo de Guzman. After pleading not guilty, the prosecution presented its evidence. The defense sought, but was denied leave to file, a demurrer to evidence, yet proceeded to file it. Subsequently, on November 19, 1991, the Sandiganbayan (Second Division) rendered a judgment finding the petitioner guilty beyond reasonable doubt of violating Section 3(e) of R.A. No. 3019. He was sentenced to imprisonment, perpetual disqualification from public office, and ordered to indemnify the government. The Petition: Petitioner seeks reversal of his conviction, arguing that his guilt was not proven beyond reasonable doubt and that the Sandiganbayan erred in basing its conviction on inconclusive evidence and giving undue credence to a lone prosecution witness over documentary evidence of lawful disbursement. He contends that the constitutional presumption of innocence was disregarded. The petition specifically faults the Sandiganbayan for concluding guilt based on the petitioner's failure to produce receipts, asserting that the prosecution should have proven the non-existence of such disbursements or the absence of the training programs, rather than placing the burden of proof on the accused.
Issue(s)
Whether the petitioner's guilt for violation of Section 3(e) of Republic Act No. 3019 was proven beyond reasonable doubt. Whether the Sandiganbayan erred in convicting the petitioner based on the evidence presented.
Ruling
The petition is DENIED. The conviction of Domingo de Guzman for violation of Section 3(e) of Republic Act No. 3019 is affirmed. He is sentenced to suffer an indeterminate penalty of imprisonment ranging from six (6) years and one (1) month to nine (9) years and one (1) day, with perpetual disqualification from public office, to indemnify the Government in the amount of P200,000.00, and to pay the costs.
Ratio Decidendi
On whether the petitioner's guilt was proven beyond reasonable doubt: The Supreme Court held that the evidence was sufficient to convict the petitioner. The petitioner admitted receiving the P200,000.00. However, he failed to present any positive evidence that the training programs in Ipil, Zamboanga del Sur, and Baguio City were actually conducted. Crucially, he did not produce any supporting receipts for the alleged disbursements, nor did he demonstrate that no undue injury was caused to the Government. This failure to account for the funds, coupled with the testimony of Josephine Angeles, the training officer who had no knowledge of such programs, established a violation of Section 3(e) of Republic Act No. 3019. The Court emphasized that the petitioner's claim that the training programs might have been held without her knowledge was mere conjecture and insufficient to overcome the prosecution's evidence. The Court reiterated that the presumption of innocence is not absolute and yields to contrary evidence of guilt, which was amply established in this case. On whether the Sandiganbayan erred in its conviction: The Supreme Court found no error in the Sandiganbayan's conviction. The petitioner's argument that the prosecution must prove the non-existence of supporting receipts was deemed a strange manner of accounting. The Court agreed with the Sandiganbayan's conclusion that the petitioner's attempt to liquidate the cash advance via a disbursement voucher without supporting receipts or testimonial/documentary evidence to justify the expenses constituted misappropriation for personal use or benefit. The certification on the disbursement voucher that it was "supported by documents, appearing legal and proper" was considered insufficient without the actual supporting documents being presented or explained. The Court stressed that the petitioner, having received government funds, had the burden to prove their lawful disbursement, not merely speculate about the possibility of training programs being held.
Main Doctrine
A public officer who receives government funds for official purposes and fails to liquidate the same with supporting receipts, despite demands, may be convicted of violating Section 3(e) of Republic Act No. 3019 if the prosecution proves beyond reasonable doubt that such failure caused undue injury to the government or gave unwarranted benefits through manifest partiality, evident bad faith, or gross inexcusable negligence. The presumption of innocence yields to sufficient contrary evidence.