**Facts:**
This case began with joint affidavit-complaints filed by the Vice Mayor and Councilors of the Municipality of Castillejos, Zambales, accusing former Mayor Teofilo G. Pantaleon, Jr. and Treasurer Jaime F. Vallejos of illegally disbursing and misappropriating public funds totaling P411,341.20 for three fictitious construction projects. These projects were documented through falsified supporting documents. Despite a lack of authorization from the municipal accountant and budget officer and non-existent projects, funds were disbursed. The Office of the Special Prosecutor recommended charges, leading to three Informations for Malversation of Public Funds through Falsification of Public Documents being filed against Pantaleon and Vallejos by the Office of the Ombudsman. The defendants pled not guilty, and the case proceeded to trial at the Sandiganbayan, where a plethora of witnesses testified for both the prosecution and defense. Despite motions for reconsideration, the Sandiganbayan found the appellants guilty, setting a series of appeals in motion, ultimately leading to the Supreme Court.
**Issues:**
1. Whether the Sandiganbayan erred in convicting Vallejos despite his position not being within salary grade 27 or higher.
2. Whether the Sandiganbayan erred in its ruling without a notice to restitute from the Provincial Auditor of Zambales.
3. Whether the Sandiganbayan erred in finding a conspiracy between Pantaleon and Vallejos.
**Court’s Decision:**
1. **Jurisdiction:** The Court upheld the Sandiganbayan’s jurisdiction, anchored on Pantaleon’s position, which corresponded to a salary grade 27.
2. **Notice to Restitute:** The absence of a notice to restitute was moot since the crime of malversation under Article 217 of the Revised Penal Code does not necessitate demand as an element for its commission.
3. **Conspiracy:** The Court affirmed the existence of a conspiracy between Pantaleon and Vallejos, evidenced by their coordinated actions facilitating the illegal disbursement despite knowledge of the non-existence of the projects and the lack of requisite signatures.
**Doctrine:**
This case established that in crimes involving malversation through falsification by public officials, conspiracy can be deduced from their coordinated actions, leading to the unlawful disbursement of public funds. Particularly, the Court emphasized Article 217 of the Revised Penal Code, articulating the elements necessary for malversation to be established.
**Class Notes:**
– **Malversation of Public Funds:** Involves (a) a public officer; (b) custody or control of funds or property by reason of office; (c) the funds or property are public; and (d) an act of appropriation, taking, misappropriating, or consenting, or through abandonment or negligence, letting another take them.
– **Falsification by Public Officer:** Occurs when a public officer, by advantage of their position, falsifies a document by causing it to appear that persons participated in an act or proceeding when they did not, or by altering true dates (Article 171, RPC).
– **Conspiracy:** Demonstrated through actions before, during, and after the commission of the crime, showing a joint purpose, concerted action, and concurrence of sentiments.
**Historical Background:**
This case underscores the Philippines’ continued battle against corruption within its public administration system. It illustrates the legal mechanisms employed to hold public officials accountable for the malversation of public funds and falsification of public documents, emphasizing the judiciary’s role in interpreting and applying complex legal provisions related to public accountability and anti-corruption measures.
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