G.R. No. 110547 -50 & G.R. Nos. 114526-667. June 26, 2001.
JOSE SAYSON Y DELARMENTE, petitioner, vs. SANDIGANBAYAN and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Jose Sayson y Delarmente was a budget examiner at the Ministry of Public Highways, Region VII, Cebu City in 1977. He was charged in two sets of cases (totaling 207 related cases) before the Sandiganbayan for violation of Section 3(e) of Republic Act No. 3019 , as amended. The charges alleged that he, in conspiracy with other public officers, caused undue injury to the government by causing, allowing, approving, and receiving illegal disbursements of public funds through fake Letters of Advice of Allotments (LAAs). The disbursements were for amounts of P47,583.31 and P49,725.00 via specific treasury checks in 1977. Petitioner pleaded not guilty. An investigation by the Commission on Audit (COA) uncovered a scheme where simulated LAAs were prepared and sold to contractors at 26% of the gross amount. State witness Delia Preagido testified that on Saturdays, she, along with accused Cruz and petitioner Sayson, would prepare and sell these fake LAAs, with petitioner and Cruz responsible for negotiating them. The fake LAAs were signed by other accused officials and did not bear proper releasing stamps or sequence numbers. Petitioner’s defense consisted of a denial, claiming the charges were politically motivated, and he argued that the Sandiganbayan had no jurisdiction as his salary grade was below 27. The Sandiganbayan convicted him in all cases.

ISSUE

The primary issue is whether the Sandiganbayan correctly found petitioner Jose Sayson guilty beyond reasonable doubt of violating Section 3(e) of R.A. No. 3019 .

RULING

The Supreme Court affirmed the decision of the Sandiganbayan. The Court held that the Sandiganbayan had jurisdiction over the case as the charges involved violations of R.A. No. 3019 , over which it has original jurisdiction regardless of the accused’s salary grade. The Court found the testimony of state witness Delia Preagido credible and sufficient to establish conspiracy. Her testimony detailed petitioner’s active participation in the preparation and sale of fake LAAs. The defense of denial was deemed weak and could not prevail over the positive identification and detailed account of the witness. All elements of the crime under Section 3(e) of R.A. No. 3019 were present: petitioner was a public officer, his actions were done in the discharge of his official functions, they caused undue injury to the government, and were done with evident bad faith. The Court also upheld the discharge of Preagido as a state witness, finding it in accordance with the rules. The penalties imposed by the Sandiganbayan were affirmed.