G.R. No. L-52352-57, June 30, 1987
Valentino G. Castillo vs. The Honorable Sandiganbayan and The People of the Philippines

FACTS

Petitioner Valentino G. Castillo, the City Engineer of Tagbilaran City, was convicted by the Sandiganbayan on six counts of Estafa through Falsification of Public Documents. The cases stemmed from the alleged fraudulent procurement of construction materials for a city project. The prosecution asserted that Castillo and his co-accused conspired to prepare and sign falsified public documents, including purchase orders, delivery receipts, and vouchers, to make it appear that materials were delivered by certain suppliers. These falsified documents were then used to support disbursement vouchers, leading to the illegal release and misappropriation of public funds.
Castillo appealed, arguing that the Sandiganbayan lacked jurisdiction as the imposable penalty did not exceed six years, and that the evidence was insufficient to prove conspiracy and his guilt beyond reasonable doubt. He contended his signatures on the documents were merely ministerial, certifying that the materials were necessary for the project, not that they were actually delivered. He claimed no knowledge of the falsifications allegedly perpetrated by his subordinates and co-accused.

ISSUE

The primary issues were: (1) whether the Sandiganbayan had jurisdiction over the cases; and (2) whether the evidence sufficiently established Castillo’s guilt as a co-conspirator in the complex crime of Estafa through Falsification of Public Documents.

RULING

The Supreme Court affirmed the Sandiganbayan’s decision. On jurisdiction, the Court held that the Sandiganbayan correctly exercised jurisdiction. While the penalty for simple estafa might not exceed six years, the charges involved the complex crime of estafa through falsification. For this complex crime under Article 48 of the Revised Penal Code, the penalty is for the most serious offense, which is falsification under Article 171, in its maximum period. This penalty exceeds six years, thus falling within the Sandiganbayan’s exclusive original jurisdiction under Presidential Decree No. 1606.
On the merits, the Court found the evidence of conspiracy and Castillo’s guilt conclusive. The legal logic centered on his role and duties as City Engineer. His signatures on the disbursement vouchers and supporting documents were not merely ministerial. By certifying that “the materials have been inspected, found in order, and duly delivered,” he made an affirmative declaration of fact essential to the fraudulent scheme. His position demanded diligence and scrutiny; his failure to verify the actual deliveries, despite glaring irregularities and the sheer volume of transactions, demonstrated gross negligence amounting to bad faith or at least implied conspiracy. The Court ruled that his actions facilitated the fraud, and his defense of ignorance was untenable given his direct participation in the approval chain. The findings of fact by the Sandiganbayan, being supported by substantial evidence, were thus upheld.