People v. Saguin
REITERATIONFacts
The Antecedents: Petitioners Editha B. Saguin (Accountant II) and Lani D. Grado (Cashier), along with Ruby C. Dalman (Administrative Officer II), all of Rizal Memorial District Hospital (RMDH), were charged with violation of Section 23 of Presidential Decree (P.D.) No. 1752, as amended by Republic Act (R.A.) No. 7742, for allegedly failing to remit Home Development Mutual Fund (HDMF) contributions and loan repayments amounting to ₱7,965.58 and ₱15,818.81, respectively, for the month of March 1993. The prosecution alleged that these amounts were deducted from the salaries of RMDH employees but were not remitted to the HDMF, causing penalties and surcharges. Procedural History: The Municipal Trial Court in Cities (MTCC) convicted all three accused. The Regional Trial Court (RTC) affirmed the conviction but modified the penalty. The Sandiganbayan, in turn, affirmed the RTC's decision, finding the accused guilty beyond reasonable doubt. The Sandiganbayan noted that the subsequent repeal of P.D. No. 1752 by R.A. No. 9679 did not absolve the accused as the provisions were reenacted. The Sandiganbayan also deleted the award of civil indemnity due to the institution of a separate civil action. The Petition: Petitioners Saguin and Grado filed a petition for review on certiorari before the Supreme Court, assailing the Sandiganbayan's decision. They argued that the penal provision applied only to 'employers' or corporate officers, not to ordinary employees like them. They also contended that R.A. No. 9679 only provided penal sanctions for 'other officials and employees' in 2009, and that the 'devolution' of the hospital to the Provincial Government of Zamboanga del Norte relieved them of responsibility for the March 1993 remittances.
Issue(s)
Whether the Sandiganbayan committed reversible errors warranting the exoneration of the petitioners from criminal liability. Whether the petitioners, as ordinary employees, could be held liable under Section 23 of P.D. No. 1752, as amended. Whether the devolution of the hospital to the Provincial Government constituted a lawful cause for the failure to remit HDMF contributions and loan payments for March 1993. Whether the prosecution proved the guilt of the petitioners beyond reasonable doubt.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision of the Sandiganbayan, and acquitted petitioners Editha B. Saguin and Lani D. Grado. The disposition was made without prejudice to their administrative and/or civil liabilities, if warranted.
Ratio Decidendi
On the issue of whether the Sandiganbayan committed reversible errors warranting exoneration: The Court found that the Sandiganbayan committed a misapprehension of facts, leading to the conclusion that the petitioners' guilt was not proven beyond reasonable doubt. The Court emphasized that while it generally does not review factual questions in petitions for review on certiorari, exceptions exist, including misapprehension of facts. The Court noted that the petitioners' case fell under these exceptions. On the issue of whether the petitioners could be held liable under Section 23 of P.D. No. 1752, as amended: The Court clarified that Section 23 of P.D. No. 1752, as amended, punishes refusal or failure to comply with the law "without lawful cause or with fraudulent intent." The Court found that the prosecution failed to prove that the failure to remit was without lawful cause or with fraudulent intent. The Court highlighted that the deductions were made, and there was no evidence that the petitioners misappropriated the funds. On the issue of whether the devolution constituted a lawful cause for the failure to remit: The Court found that the devolution of the Rizal Memorial District Hospital (RMDH) to the Provincial Government of Zamboanga del Norte on April 1, 1993, constituted a lawful cause for the petitioners' inability to make the HDMF remittances for March 1993. The remittances for the second quincena payroll of March 1993 were due in April 1993. Following the devolution, financial transactions were handled by the Provincial Government, and the petitioners reasonably believed that the duty to remit was transferred. They were no longer in control of the financial operations or authorized to issue checks for such remittances. On the issue of whether the prosecution proved guilt beyond reasonable doubt: The Court concluded that the prosecution failed to prove the guilt of the petitioners beyond reasonable doubt. The Court reiterated the constitutional presumption of innocence and the imperative of proof beyond reasonable doubt. Given the lawful cause (devolution) for the non-remittance and the absence of fraudulent intent, any doubt must be resolved in favor of the petitioners. The Court stated that while there was noncompliance, the circumstances surrounding the devolution created a doubt that warranted acquittal.
Main Doctrine
The failure to remit HDMF contributions and loan payments, while punishable under P.D. No. 1752, as amended, requires proof that such failure was without lawful cause or with fraudulent intent. The devolution of a hospital to a provincial government, which results in the transfer of financial control and operations, can constitute a lawful cause for the inability of hospital employees to effect such remittances, thereby negating criminal liability.