In People vs. Pajaro, the Supreme Court affirmed the conviction of municipal officials for malversation of public funds through falsification of public documents and violation of the Anti-Graft and Corrupt Practices Act. This case underscores the severe consequences for public officials who abuse their positions of trust by misappropriating government funds and falsifying documents to cover their tracks. It reinforces the importance of transparency, accountability, and adherence to established procedures in the management of public resources.
Public Funds Betrayal: Can Local Officials Be Held Liable for Falsified Livelihood Projects?
The case revolves around Teddy M. Pajaro, the former Municipal Mayor of Lantapan, Bukidnon, along with Crispina P. Aben, the acting Municipal Accountant, and Flor S. Libertad, the Municipal Treasurer. From 1989 to 1998, these officials were found guilty of causing the irregular disbursement of public funds for livelihood projects and the IEC-Peace and Order Program, totaling P179,000.00 and P140,000.00 respectively. An audit revealed that P74,000.00 of the disbursed funds was not received by the intended beneficiaries, who were selected arbitrarily, and that the disbursements were processed irregularly, causing prejudice to the local government. The Office of the Ombudsman filed four Informations for Malversation of Public Funds and two Informations for violation of Section 3(e) of Republic Act No. 3019 against the appellants.
At trial, State Auditor Rogelio Tero testified about the findings in the audit report. The auditor stated that a significant portion of the funds intended for livelihood projects, amounting to P74,000.00, never reached the intended beneficiaries. Additionally, the disbursement vouchers lacked proper certification from the Municipal Budget Officer, bypassing standard procedures. Crucially, the auditor stressed the importance of the budget officer’s certification as a mandatory requirement for the lawful disbursement of public funds, according to the COA’s rules and regulations.
The appellants defended their actions by claiming that the disbursements were made following Resolutions issued by the Sangguniang Bayan of Lantapan and the Municipal Development Council. They argued that the lack of certification from the Municipal Budget Officer was due to his refusal to sign the documents, despite the presence of supporting papers. However, the Sandiganbayan ruled against them, citing inconsistencies in the signatures of the alleged beneficiaries and finding that the appellants conspired to defraud the government.
The Sandiganbayan found that there were blatant differences in the signatures of the supposed beneficiaries in the disbursement vouchers compared to their actual signatures in other documents. These variations served as strong evidence that the signatures on the vouchers were indeed falsified. The court underscored the critical role each appellant played in facilitating the illegal release of funds. Mayor Pajaro approved the disbursement vouchers, while Acting Municipal Accountant Aben obligated the allotments despite the absence of budget officer certification. Adding to the fraudulent scheme, Municipal Treasurer Libertad released the funds without the required certification. Each person’s deliberate act contributed to the malversation and underscored a shared intent to commit fraud.
The Supreme Court upheld the Sandiganbayan’s decision, emphasizing that the combined actions of the appellants demonstrated a clear conspiracy to defraud the government. The Court reiterated the elements of malversation of public funds, which include being a public officer, having custody or control of funds by reason of office, the funds being public, and the misappropriation or consent to another person taking the funds. Similarly, it upheld the conviction for violation of Section 3(e) of Republic Act No. 3019, requiring that the accused be a public officer, acted with manifest partiality or evident bad faith, and caused undue injury to the government. The evidence showed clear breaches of established procedures and the falsification of documents.
FAQs
| What were the charges against the appellants? | The appellants were charged with malversation of public funds through falsification of public documents and violation of Section 3(e) of the Anti-Graft and Corrupt Practices Act. |
| Who were the appellants in this case? | The appellants were Teddy M. Pajaro, the Municipal Mayor; Crispina P. Aben, the acting Municipal Accountant; and Flor S. Libertad, the Municipal Treasurer. |
| What was the total amount of funds involved? | The case involved P179,000.00 for livelihood projects and P140,000.00 for the IEC-Peace and Order Program, totaling P319,000.00. |
| What was the role of the budget officer in fund disbursements? | The budget officer’s certification is a mandatory requirement for the disbursement of public funds, ensuring there’s an appropriation legally made for the purpose. |
| How did the court determine that the signatures were falsified? | The court compared the signatures on the disbursement vouchers with those in other documents and found evident differences, leading to the conclusion that the signatures were falsified. |
| What is required to prove the violation of Section 3(e) of RA 3019? | It must be proven that the accused is a public officer, acted with manifest partiality or evident bad faith, and caused undue injury to any party, including the government. |
| What is COA Circular 92-382? | COA Circular No. 92-382 outlines the accounting and auditing rules for the disbursement of local funds, specifying procedures and required certifications. |
| What was the decision of the Supreme Court? | The Supreme Court upheld the Sandiganbayan’s decision, affirming the conviction of the appellants for malversation of public funds and violation of the Anti-Graft and Corrupt Practices Act. |
The case underscores the serious consequences of mismanaging public funds and emphasizes the importance of adhering to established procedures in handling government resources. Public officials are expected to maintain the highest standards of integrity, accountability, and transparency. This case serves as a critical lesson for those in positions of public trust.
For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines vs. Teddy M. Pajaro, G.R. Nos. 167860-65, June 17, 2008
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