**Jaime H. Domingo and Diosdado T. Garcia vs. People of the Philippines**
### Facts:
**Background and Initial Developments:**
– **1993:** Jaime H. Domingo served as mayor of San Manuel, Isabela. A Multi-Purpose Pavement (MPP) project was initiated with a P520,000 budget from the 20% Economic Development Fund (EDF). Rep. Faustino Dy, Jr. donated 3,600 bags of cement for the project. Additional materials and labor were provided by the municipality and barangays.
– **June 1994:** COA Regional Director Pedro M. Guiang, Jr. formed a special audit team to examine the municipality’s infrastructure and EDF expenditures for 1993.
– **October 1994:** The audit revealed irregularities, including suspicious checks and mismatches in documents.
**Problematic Transactions:**
– **Checks Involved:** Two checks (PNB No. 901363-S for P114,350 and PNB No. 901365-S for P20,000) were issued to Domingo, though the disbursement voucher listed D.T. Garcia Construction Supply as the claimant.
– **Irregularities Noticed:** The audit team identified no contract existed between San Manuel and D.T. Garcia Construction Supply, indicated violations of procurement rules, undocumented disbursement vouchers, and unauthorized usage of Domingo’s trucks for materials delivery.
**Legal Actions Initiated:**
– **November 1996:** A Motion for Reinvestigation led to Garcia being charged alongside Domingo. The Sandiganbayan admitted an amended information, incorporating Garcia into the charge of conspiracy for violating Sec. 3(h) of R.A. 3019 (Anti-Graft and Corrupt Practices Act).
**Trial and Testimonies:**
– **Initial Witnesses:** Prosecution presented COA auditors who reported on their findings.
– **Defendant’s Evidence:** Domingo presented a contract and an emergency purchase certificate to justify the transactions without bidding and established checks as partial indebtedness payments.
– **Contradictory Statements:** Garcia initially supported Domingo during the preliminary investigation but later retracted, claiming the absence of any contract and a coerced narrative.
### Issues:
1. **Sufficiency of Evidence:** Whether the evidence was sufficient to prove beyond reasonable doubt that Domingo and Garcia violated Section 3(h) of R.A. 3019.
2. **Existence of Conspiracy:** Whether there was enough proof of conspiracy between Domingo and Garcia to justify their convictions.
3. **Classification of Garcia’s Liability:** Whether Garcia should be considered only an accessory to the crime instead of a principal by indispensable cooperation.
### Court’s Decision:
**Issue 1: Sufficiency of Evidence:**
– **Finding:** The Sandiganbayan found the actions and testaments provided sufficient evidence that Domingo intervened in his capacity to benefit from the contract. Documents were irregular, and the checks indicated personal benefit.
– **Conclusion:** Domingo had financial interest and intervened inappropriately, violating Section 3(h) of R.A. 3019.
**Issue 2: Existence of Conspiracy:**
– **Finding:** Conspiracy was inferred through Garcia’s active participation and the collaborative actions taken to cover up the fraudulent transactions.
– **Conclusion:** Both Domingo and Garcia were found guilty as conspirators.
**Issue 3: Classification of Garcia’s Liability:**
– **Finding:** Garcia not only aided but actively partook in the scheme’s execution, making him equally liable as a principal by indispensable cooperation.
– **Conclusion:** The Court affirmed Garcia’s conviction as a co-conspirator.
**Final Decision:** The Supreme Court affirmed the Sandiganbayan’s decision, convicting both Domingo and Garcia and upholding the imprisonment and perpetual disqualification from public office as prescribed by R.A. 3019.
### Doctrine:
– **Anti-Graft and Corrupt Practices Act (R.A. 3019 Sec. 3(h)):** A public officer having direct or indirect financial interest in a business or transaction where he intervenes in his official capacity is unlawful.
– **Conspiracy Doctrine:** Established through concerted actions intending to commit the crime, implicating all involved parties as equally liable.
### Class Notes:
1. **Corrupt Practices (R.A. 3019 Sec. 3(h)):** Essential elements include:
– Accused is a public officer.
– Has direct/indirect financial or pecuniary interest.
– Intervenes/takes part in official capacity or is prohibited by law.
2. **Conspiracy:**
– Formed by agreement or concerted actions.
– Equal liability for all conspirators regardless of the role.
3. **Relevant Statutes:**
– Local Government Code of 1991.
– Government Accounting and Auditing Manual.
### Historical Background:
– **Context:** A part of the ongoing efforts to curb corruption in public office in the Philippines. Policies and enhanced oversight mechanisms reflect the country’s struggle with historical graft in local governance.
– **Cultural Impact:** Reinforces vigilance against the misuse of local government funds for public trust protection and integrity preservation in office.
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