G.R. No. 233152 , July 13, 2020
Dionisio B. Coloma, Jr., Petitioner, vs. People of the Philippines and Sandiganbayan (Fourth Division), Respondents.

FACTS

Petitioner Police Chief Superintendent Dionisio B. Coloma, Jr., then Deputy Director of the Philippine National Training Institute (PNTI), Philippine Public Safety College (PPSC), was charged with violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act). The Amended Information alleged that between June and October 2001, in Bongao, Tawi-Tawi, Coloma, in his official capacity overseeing the construction of a training school annex, gave unwarranted benefit to spouses Rolando Lim and Albia J. Lim (of A.C. Lim Construction) and caused undue injury to PPSC by purchasing a 10,000-square-meter property from them for ₱1,500,000.00 using public funds. The purchase was made despite: (a) lack of prior PPSC authority; (b) absence of public bidding or survey for alternative properties; (c) no documents establishing the Lim spouses’ ownership; (d) no deed of sale prior to payment; (e) failure to consider a municipal government lot allocated for the school; and (f) disregard of the market value of land in Bongao (₱9,730 per hectare). The prosecution established that funds for the Regional Training School (RTS-9) Annex in Tawi-Tawi, sourced from a congressman’s Community Development Fund, had no provision for land acquisition. Coloma suggested purchasing the land from the Lim spouses, with the amount to be taken from the construction budget and disguised as a donation. He facilitated the transfer of funds to a joint account with the contractor, issued a check for mobilization, and reported the project as 100% complete to the DBM despite incomplete status. An investigation later revealed the land was bought by Mrs. Lim for only ₱10,000, and a municipal resolution had earlier allocated land for the school. Coloma pleaded not guilty, and the Sandiganbayan found him guilty, which he appealed.

ISSUE

Whether the Sandiganbayan erred in finding petitioner Dionisio B. Coloma, Jr. guilty beyond reasonable doubt of violating Section 3(e) of R.A. No. 3019 .

RULING

The Supreme Court denied the petition and affirmed the Sandiganbayan’s Decision and Resolution. The Court held that all elements of violation of Section 3(e) of R.A. No. 3019 were present: (1) Coloma was a public officer discharging administrative functions; (2) he acted with manifest partiality, evident bad faith, or gross inexcusable negligence; and (3) his actions caused undue injury to the government or gave unwarranted benefits to a private party. Coloma’s actions—purchasing overpriced land without authority, bidding, or proper documentation, ignoring a free municipal lot, and diverting construction funds for the purchase—demonstrated manifest partiality and bad faith, favoring the Lim spouses. His claim of good faith was rejected, as he failed to follow standard procedures and exercised undue discretion. The Court found no reason to overturn the Sandiganbayan’s factual findings, which were supported by evidence, and noted the case’s similarity to a prior ruling against Coloma. Thus, his conviction was upheld.