G.R. No. 235418. March 03, 2021 (Case Brief / Digest)

### Title: Antonio M. Suba vs. Sandiganbayan and People of the Philippines

### Facts:
Antonio M. Suba, the petitioner, and Roberto R. Navida, both officials of the Philippine Aerospace Development Corporation (PADC), sought to attend the 4th Biennial International Aircraft Conversion and Maintenance Conference in Beijing, China in 2006. Despite a denied travel authority from the Department of Transportation and Communications (DOTC) due to an existing suspension on foreign travels and lacking required supporting papers, Suba and Navida proceeded with the travel funded by the government through approved cash advances. Upon their return, a Commission on Audit (COA) State Auditor issued a Notice of Suspension for deficiencies in Suba’s cash advances, which later escalated to a Notice of Disallowance making Suba, Navida, and three others liable for the unliquidated amount of P241,478.68. Suba’s motion for reconsideration was denied, leading to a Notice of Finality of Decision in 2010. Suba settled the disallowed amount in 2014. Concurrently, an anonymous complaint led the Office of the Ombudsman to investigate and eventually file a complaint against Suba and others for violation of Section 3(e) of Republic Act No. 3019. Despite Suba’s defense of reliance on verbal assurance from Navida about the travel authority and his repayment of the disallowed amount, the Sandiganbayan found him guilty, a decision confirmed upon his motion for reconsideration.

### Issues:
1. Whether the Sandiganbayan erred in convicting Suba for violating Section 3(e) of R.A. No. 3019 based on evident bad faith, manifest partiality, and/or gross inexcusable negligence.
2. If Suba’s actions constituted giving undue injury to the government and/or giving unwarranted benefits using government funds without proper travel authority.
3. Whether the prosecution failed to establish the guilt of Suba beyond reasonable doubt for the crime charged.

### Court’s Decision:
The Supreme Court reversed the Sandiganbayan’s decision, finding no sufficient evidence of Suba’s criminal liability under Section 3(e) of R.A. No. 3019. The Court pointed out that bad faith implies a dishonest purpose or moral obliquity, which was not established in Suba’s conduct. It acknowledged that Suba attended the conference for purposes relevant to PADC operations and had settled the disallowed amount post-disallowance finality. The Court emphasized the prosecution’s inability to prove beyond reasonable doubt that Suba was aware of the travel authority’s denial or had any ill motive in proceeding with the travel. Thus, Suba was acquitted of the charges.

### Doctrine:
The case reiterated the doctrine concerning “evident bad faith” in the context of Section 3(e) of R.A. No. 3019, defining it as an act with a palpably dishonest purpose or some moral obliquity, consciously wrong for a perverse motive, or ill will—emphasizing that mistakes or errors in judgment by public officials do not automatically imply bad faith.

### Class Notes:
– The elements required to convict under Section 3(e) of R.A. No. 3019 include the offender being a public officer acting with evident bad faith, manifest partiality, or gross inexcusable negligence that causes undue injury to any party, including the government.
– “Evident bad faith” denotes a deliberate intent to do wrong, characterized by dishonest or fraudulent motives rather than mere errors in judgment.
– The presumption of innocence remains paramount in criminal proceedings, with the burden of proof resting squarely on the prosecution to establish guilt beyond reasonable doubt.
– Restitution or settlement of disallowed amounts does not necessarily negate the possibility of bad faith but may be considered in assessing the accused’s intent or guilt.

### Historical Background:
This case underscores the stringent requirements for proving corruption and the misuse of public funds under Philippine law, specifically under the Anti-Graft and Corrupt Practices Act (R.A. No. 3019). It highlights the judiciary’s role in scrutinizing the evidence for allegations of corruption, ensuring that convictions are based on unequivocal proof of guilt, and reiterating the importance of the presumption of innocence and the protections afforded to accused individuals under the law.


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