G.R. No. 144950 . March 22, 2007.
BLAS BALDEBRIN and PERPETUO LACEA, Petitioners, vs. SANDIGANBAYAN (Third Division) and PEOPLE OF THE PHILIPPINES, Respondents.

FACTS

Petitioners Blas Baldebrin, Administrative Officer I, and Perpetuo Lacea, Civil Engineer, of the Negros Oriental Highway Engineering District (NOHED), were among numerous public officials and private contractors charged with multiple counts of violating Section 3(e) of R.A. No. 3019 (Anti-Graft Act). The charges stemmed from a widespread scheme involving “ghost” deliveries of materials for highway projects in Region VII during the late 1970s. The Informations alleged that the accused, in conspiracy, falsified public documents—including vouchers, purchase orders, and delivery receipts—to simulate payments for non-existent deliveries, thereby causing undue injury to the government.
A Special Task Force investigation revealed that the illegal disbursements in NOHED were facilitated through the splitting of requisitions to avoid required approvals and public bidding, and the use of falsified supporting documents. Specific vouchers, funded based on these fake documents, were charged against government allotments. Petitioners, as administrative officer and field supervisor, were implicated in this conspiracy to defraud the government through simulated transactions.

ISSUE

Whether the Sandiganbayan correctly convicted petitioners of violating Section 3(e) of R.A. No. 3019 based on conspiracy and the existence of simulated transactions causing undue injury to the government.

RULING

Yes, the Supreme Court affirmed the Sandiganbayan’s conviction. The Court found that all elements of Section 3(e) were present: petitioners were public officers; they acted with evident bad faith; their actions caused undue injury to the government; and they conspired with other accused. The prosecution successfully established a conspiracy through the coordinated actions of the accused in preparing, approving, and processing falsified documents for “ghost” deliveries. The splitting of requisitions and the use of fabricated supporting documents were part of a deliberate scheme to illegally disburse public funds.
Petitioners’ specific roles were integral to the conspiracy. As administrative officer and field supervisor, their participation in the processing chain was necessary to give a semblance of legality to the fraudulent transactions. The Court emphasized that in conspiracy, direct proof of agreement is not essential; it can be inferred from the conduct of the accused indicating a common purpose. The collective actions of petitioners and their co-accused, resulting in the government paying for non-existent supplies, unequivocally demonstrated this common criminal design. Their conviction was thus upheld, as the evidence proved beyond reasonable doubt their guilt for causing undue injury through evident bad faith.