G.R. Nos. L-52872-52997 January 30, 1987
ROLANDO R. MANGUBAT, petitioner, vs. THE HONORABLE SANDIGANBAYAN AND THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Between March 1 and April 4, 1979, 126 identically worded informations were filed with the Sandiganbayan, charging several officials of the Ministry of Public Highways, Region VII, and the Danao City Highway Engineering District, along with private suppliers, with Estafa through Falsification of Public Documents. Petitioner Rolando Mangubat was the Chief Accountant I of Region VII. The charges alleged a conspiracy from January to July 1978, wherein the accused officials falsified Letters of Advice of Allotment (LAAs), Requests for Obligation of Allotment, Purchase Orders, Delivery Receipts, and other public documents to make it appear that the Danao HED had proper funding and that construction materials were duly delivered and inspected. In truth, no such deliveries occurred. Through these falsifications, the accused were able to collect and misappropriate over P6.2 million from the government.
After a joint trial, the Sandiganbayan convicted most of the accused, including Mangubat, sentencing him in each case to an indeterminate penalty and ordering him to indemnify the government. Mangubat filed a motion for reconsideration, which was denied. He then filed the instant petition, challenging the decision on legal and factual grounds.

ISSUE

The primary issues are: (1) whether the law creating the Sandiganbayan is constitutional, and (2) whether the evidence is sufficient to sustain Mangubat’s conviction, particularly regarding his role in the conspiracy.

RULING

The Supreme Court dismissed the petition and affirmed the Sandiganbayan’s decision. On the legal issue, the Court held that the challenge to the constitutionality of the Sandiganbayan’s creation law was already settled in Nuñez vs. Sandiganbayan. The Court reiterated that the law does not violate the constitutional guarantees of equal protection, due process, or the prohibition against ex post facto laws. The Sandiganbayan is a valid special court with jurisdiction over public officers.
On the factual issue, the Court found the evidence of Mangubat’s guilt, particularly his participation in the conspiracy, to be overwhelming. The scheme to defraud the government required the issuance of fake LAAs and Cash Disbursement Ceilings (CDCs) to authorize the Danao HED to incur obligations and make disbursements for non-existent deliveries. As the Chief Accountant, Mangubat signed these falsified LAAs and CDCs. His signatures were indispensable, as they initiated the entire fraudulent process. The Sandiganbayan correctly noted that he certified trial balances as true and complete despite the manipulations recorded in them and could not satisfactorily explain glaring errors in journal vouchers under his responsibility.
The Court upheld the finding of conspiracy. The defraudation was a coordinated effort involving officials from both the regional and district offices, each performing specific acts to achieve the common criminal objective. Mangubat’s act of issuing the false LAAs was a concerted and cooperative action with the others, demonstrating a unity of purpose. Where defendants by their acts aim at the same object, performing different parts to complete it, their acts, though seemingly independent, are deemed concerted, establishing conspiracy. Therefore, Mangubat is liable for all 126 cases.