GR 81563; (December, 1989) (Digest)
G.R. No. 81563 & G.R. No. 82512, December 19, 1989
Amado C. Arias and Cresencio D. Data, petitioners, vs. The Sandiganbayan, respondent.
FACTS
The petitioners, Amado C. Arias and Cresencio D. Data, were among several public officials convicted by the Sandiganbayan for violating the Anti-Graft and Corrupt Practices Act. The case stemmed from the negotiated purchase of a 19,004-square-meter parcel of land in Pasig for the Mangahan Floodway Project. The prosecution alleged that the government suffered undue injury by paying P80.00 per square meter in 1978, which was grossly overpriced compared to the property’s assessed value of P5.00 per square meter as stated in its 1973 tax declaration. The Sandiganbayan found the petitioners, who held approving and certifying roles in the transaction, guilty as co-conspirators for having approved the disbursement based on supporting documents that were later alleged to be spurious.
ISSUE
Whether the petitioners are guilty beyond reasonable doubt of conspiracy to cause undue injury to the government through the alleged overpriced purchase of the land.
RULING
The Supreme Court ACQUITTED petitioners Arias and Data. The Court held that the evidence failed to establish their guilt beyond reasonable doubt. The legal logic centered on two key points. First, the Court found the Sandiganbayan erroneously equated the P5.00 per square meter tax assessment with the property’s true market value. The Solicitor General correctly argued that this assessed value, based solely on land use as riceland, was arbitrary and unrealistic. Testimony from the municipal assessor himself indicated the P80.00 price was reasonable given the property’s location near commercial areas and prevailing land values. The charge was for causing undue injury, not for falsification of documents. Without conclusive proof that the government actually paid more than fair market value, the core element of undue injury was not satisfied.
Second, the Court rejected the sweeping application of conspiracy. It ruled that a department head or chief auditor cannot be held criminally liable as a co-conspirator simply for approving a transaction based on routine reliance on the completeness and regularity of supporting documents prepared by subordinates. Guilt must be based on more knowing, personal, and deliberate participation. The Court cautioned that holding all signatories in a bureaucratic chain automatically liable would be unjust. The quantum of evidence did not prove that Arias and Data acted with manifest partiality, evident bad faith, or gross negligence, as their actions were consistent with the regular performance of official duty, trusting the preparatory work of their subordinates.