GR 107119; (April, 1996) (Digest)
G.R. Nos. 107119-20 and 108037-38. April 17, 1996.
TEODORO D. PAREÑO and AQUILINO T. LARIN, PETITIONERS, VS. SANDIGANBAYAN AND THE PEOPLE OF THE PHILIPPINES, RESPONDENTS.
FACTS
Petitioners Teodoro D. Pareño and Aquilino T. Larin, officials of the Bureau of Internal Revenue (BIR), were convicted by the Sandiganbayan for violating the National Internal Revenue Code (NIRC) and the Anti-Graft and Corrupt Practices Act. The case stemmed from a request by Tanduay Distillery, Inc. for a tax credit of over P180 million, claiming it erroneously paid ad valorem taxes. Larin, as Assistant Commissioner, instructed Pareño to prepare a request for verification of Tanduay’s payments. Pareño referred the task to a subordinate, who prepared a memorandum, which Larin signed, requesting the Revenue Accounting Division (RAD) to authenticate the payments. The RAD Chief, Potenciana Evangelista, certified the payments. Based on this certification, Pareño and another official recommended approval of the tax credit, which was subsequently granted.
ISSUE
Whether the Sandiganbayan erred in convicting petitioners Pareño and Larin based on the evidence presented.
RULING
Yes. The Supreme Court acquitted petitioners on grounds of reasonable doubt. The legal logic centers on the insufficiency of evidence to prove conspiracy and criminal intent beyond a reasonable doubt. For a conviction under the Anti-Graft law, there must be proof of deliberate participation in a conspiracy to cause undue injury or give unwarranted benefits. The Court found that petitioners merely performed their official, ministerial duties in the processing of Tanduay’s claim. Larin’s act of signing the verification request and Pareño’s act of referring the task were routine administrative steps, not indicative of criminal collusion. The Sandiganbayan’s inference of conspiracy was based on speculation, not on the convincing proof required in criminal cases. The Court emphasized that the presence of the RAD certification, issued by a separate office, provided a basis for the subsequent processing, and petitioners’ reliance on this subordinate’s work was in good faith. The prosecution failed to establish that petitioners acted with manifest partiality, evident bad faith, or gross negligence. Therefore, the evidence did not meet the quantum of proof needed for a moral certainty of guilt.