Matobato v. People
REITERATIONFacts
The Antecedents: The Sangguniang Bayan of Pantukan, Compostela Valley, passed Resolution No. 164, Series of 1994, authorizing the Municipal Treasurer, Silvino B. Matobato, Sr. (Silvino), to transfer municipal funds to Davao Cooperative Bank (DCB) via time deposit. Between 1994 and 1998, various amounts were transferred. DCB became insolvent in 1998, and the municipality could not withdraw the deposited funds. The Commission on Audit (COA) noted that these were treated as idle funds and recommended criminal and administrative charges against involved municipal officials. Procedural History: An Information for violation of Section 3(e) of Republic Act (RA) No. 3019 was filed against Silvino, Sangguniang Bayan members Walter B. Bucao (Walter) and Cirila A. Engbino (Cirila), and seven others. The charge alleged conspiracy and gross inexcusable negligence in authorizing the fund transfer without investigating DCB's financial status. The Sandiganbayan acquitted all accused based on reasonable doubt, finding that the prosecution failed to prove gross and inexcusable negligence. However, the Sandiganbayan declared them civilly and solidarily liable for the unrecovered funds amounting to P9.25 million, reasoning that while not criminally liable, they were negligent enough to incur civil liability due to failure to conduct due diligence. The Petition: Silvino, Walter, and Cirila filed petitions for review on certiorari, assailing the Sandiganbayan's decision regarding their civil liability. Silvino argued he was not civilly liable pending DCB's liquidation, as actual damages were not yet ascertained. Walter and Cirila contended there was no preponderant evidence and invoked the presumption of regularity in their official functions.
Issue(s)
Whether the acquittal of the accused on reasonable doubt in a criminal case for violation of RA 3019 extinguishes their civil liability. Whether Silvino B. Matobato, Sr., Walter B. Bucao, and Cirila A. Engbino are civilly liable for the unrecovered municipal funds deposited with Davao Cooperative Bank.
Ruling
The petitions are unmeritorious. The Sandiganbayan's Decision dated September 20, 2016, and Resolution dated January 11, 2017, in Criminal Case No. SB-10-CRM-0015, are affirmed.
Ratio Decidendi
On whether the acquittal on reasonable doubt extinguishes civil liability: The Court reiterated the principle that every person criminally liable is also civilly liable. However, the dismissal of a criminal action does not necessarily extinguish civil liability under specific circumstances. These include situations where the acquittal is based on reasonable doubt, as civil liability only requires proof by a preponderance of evidence. The Court emphasized that preponderance of evidence means the evidence which is more convincing and worthy of belief than the opposing evidence. In this case, the Sandiganbayan acquitted the accused due to reasonable doubt, meaning the quantum of proof required for criminal conviction was not met. Nevertheless, the quantum of proof for civil liability, which is preponderance of evidence, was met to sustain the Sandiganbayan's findings on their civil liability. On the civil liability of Silvino B. Matobato, Sr., Walter B. Bucao, and Cirila A. Engbino: The Court affirmed the Sandiganbayan's finding of civil liability. As Municipal Treasurer, Silvino was accountable for the safekeeping of municipal funds. He failed to exercise reasonable care and caution by not flagging risks, vouching for DCB's financial status despite the Asian Financial Crisis, proceeding with the investment despite DCB being a relatively new entity in a turbulent market, continuing deposits after DCB's authority expired, and failing to establish any contingent measures. The Court found that Silvino was negligent in the discharge of his duties, as supported by the Sandiganbayan's observation that he failed to conduct due diligence and ensure the safety of the funds. His contention that he could not be held liable pending liquidation was dismissed, as the municipality had already suffered damage by being unable to use the funds for public service. The Court also held Walter and Cirila liable, stating that their presumption of regularity was rebutted by their negligent participation. They relied on mere verbal assurances and failed to conduct further examination of DCB's financial statements, despite the substantial amount and risks involved. Their active participation in authorizing the deposit, without protest or serious reservations, made them accountable for the funds under Section 340 of the Local Government Code of 1991.
Main Doctrine
The dismissal of a criminal action does not necessarily extinguish civil liability, especially when the acquittal is based on reasonable doubt, as civil liability only requires proof by preponderance of evidence. Public officers remain accountable for the safekeeping of public funds and must exercise due diligence in their management, failing which they may be held civilly liable for damages.