GR 139984; (March, 2005) (Digest)
G.R. No. 139984 . March 31, 2005
LEOPOLDO OANI, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Leopoldo Oani, the principal of Panabo High School, was charged with violating Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) for causing undue injury to the government through manifest partiality, evident bad faith, or gross inexcusable negligence. The charges stemmed from several purchases made using the school’s Maintenance and Other Operating Expenses (MOOE) funds during the 1988-1989 school year. A Commission on Audit (COA) team, acting on a complaint, investigated transactions including the procurement of fire extinguishers, a stereo amplifier set, and office supplies.
The audit revealed significant overpricing. Notably, nine fire extinguishers were purchased from Powerline Manufacturing for ₱54,747.00, but a re-canvass showed they could have been procured for only ₱31,707.00, resulting in an overprice of ₱23,040.00. Similarly, a stereo amplifier set and various office supplies were found to be overpriced by tens of thousands of pesos. The prosecution alleged Oani approved these purchases without the required public bidding, directly dealing with favored suppliers and certifying the availability of funds despite alleged irregularities.
ISSUE
Whether the Sandiganbayan correctly convicted Leopoldo Oani for violation of Section 3(e) of R.A. No. 3019 .
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the elements of the crime under Section 3(e): the accused is a public officer; the act was done in the discharge of official functions; through manifest partiality, evident bad faith, or gross inexcusable negligence; and it caused undue injury to any party or gave unwarranted benefits. The Court found all elements present. Oani, as school principal, was a public officer who approved the disbursements in his official capacity.
The Court ruled that Oani acted with gross inexcusable negligence. He failed to conduct the mandatory public bidding for the purchases, a fundamental rule in government procurement designed to ensure the best price and prevent fraud. His disregard of this rule, without any valid justification, constituted gross negligence. This negligence directly resulted in undue injury to the government, as it was forced to pay inflated prices, causing financial loss. The defense’s claim of good faith was rejected, as his failure to adhere to basic procurement regulations was inexcusable. The factual findings of the Sandiganbayan on the overpricing and the absence of bidding were upheld as supported by evidence.