GR 102685; (January, 1993) (Digest)
G.R. No. 102685 January 29, 1993
MIGUEL M. MEDIJA, JR., petitioner, vs. SANDIGANBAYAN (FIRST DIVISION) AND PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Miguel M. Medija, Jr., a Mechanical Engineer employed as Engineer “A” at the National Irrigation Administration (NIA) Regional Office in Zamboanga City, was charged with violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The Information alleged that on or about March 25, 1985, he conspired with private individual Rolando Manalo, a supplier, and, through evident bad faith, caused undue injury to the government by certifying that a set of chain assembly for a bulldozer supplied by Manalo was “okay as to quantity and specification” when it was in fact only rebuilt, thereby making the government pay the brand new price of P136,800.00. After trial, the Sandiganbayan convicted Medija, sentencing him to imprisonment and ordering him to reimburse the government. His co-accused, Rolando Manalo, remained at large. Medija filed the instant petition seeking reversal of the conviction.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in convicting petitioner Miguel M. Medija, Jr., of violation of Section 3(e) of R.A. No. 3019 based on the evidence presented.
RULING
The Supreme Court SET ASIDE the decision of the Sandiganbayan and ACQUITTED Miguel M. Medija, Jr., on grounds of reasonable doubt. The Court found that the evidence on record could not sustain a verdict of guilt beyond reasonable doubt. While the information charged “evident bad faith,” the Sandiganbayan convicted Medija based on “gross inexcusable negligence.” However, the Court ruled that the evidence was insufficient to establish criminal culpability. Medija’s act of certifying the chain assembly based on a visual comparison with a sample link, though possibly lacking in care, did not conclusively prove he was part of a conspiracy to defraud the government. No positive evidence was presented to prove conspiracy or that Medija intentionally participated in a scheme to defraud. The Court noted that other responsible officers involved in the procurement and payment process were not indicted, and the government proceeded with payment even after a Commission on Audit report found the assembly was not brand new. Medija’s lack of care may be a ground for administrative action, but not for criminal conviction under the circumstances.