GR L 58327; (March, 1991) (Digest)
G.R. No. L-58327; March 22, 1991
JESUS C. BALMADRID and MILA C. BALMADRID, petitioners, vs. THE HONORABLE SANDIGANBAYAN, respondent.
FACTS
Petitioners Jesus and Mila Balmadrid, private suppliers, were charged alongside public officials Maximo Binos and Teodulo Alcantara of the Catanduanes Agricultural and Industrial College (CAIC) for violating Section 3(e) of R.A. No. 3019 (Anti-Graft Act). The information alleged a conspiracy to defraud the government college through fictitious transactions. Specifically, Binos and Alcantara, indebted to Mila Balmadrid for P9,200, devised a scheme to use CAIC funds for repayment. They prepared and antedated falsified procurement documents for ghost deliveries from the Balmadrids’ business, Ecbal Enterprises, and issued four CAIC checks payable to Mila. The Balmadrids cooperated by writing a demand letter and recording the transactions in their sales book to simulate legitimacy before encashing the checks.
ISSUE
Whether petitioners, as private individuals, can be validly convicted under Section 3(e) of R.A. No. 3019 for conspiring with public officers to cause undue injury to the government.
RULING
Yes. The Supreme Court affirmed the Sandiganbayan’s conviction. The legal logic rests on the established principle of conspiracy. While Section 3(e) primarily targets public officers, a private person may be held equally liable if they conspire with a public officer in committing the offense. Conspiracy need not be proved by direct evidence but can be inferred from the parties’ coordinated acts directed toward a common criminal objective. Here, the petitioners’ active participation—agreeing to the scheme, providing a covering demand letter, and falsifying commercial records to conceal the ghost transactions—demonstrated indispensable cooperation in the defraudation. Their acts were integral to giving the illegal disbursement a semblance of legality.
The Court emphasized that in a conspiracy, the act of one is the act of all. Consequently, petitioners, by conspiring with the public officers, assumed the same criminal liability for causing undue injury to CAIC through manifest partiality and evident bad faith. The factual findings of the Sandiganbayan, which detailed this concerted design, are binding. The petition was dismissed for lack of merit.