### Facts:
Arnold James M. Ysidoro was accused of technical malversation under Article 220 of the Revised Penal Code before the Sandiganbayan in Criminal Case 28228. As the mayor of Leyte, Leyte, he approved the diversion of food intended for malnourished children to beneficiaries of the Core Shelter Assistance Program (CSAP), aiming to aid in their ongoing construction projects following calamities. This scenario unfolded when construction work halted due to workers’ need to secure food for their families. Ysidoro’s approval led to the release of four sacks of rice and two boxes of sardines earmarked for the municipality’s Supplemental Feeding Program (SFP). This decision to divert the goods was reported following standard auditing procedures but later contested, leading Alfredo Doller to file a complaint against Ysidoro.
Ysidoro argued that the diversion was warranted due to savings in the SFP and the necessity to aid poor municipality members similarly in need. The Sandiganbayan found Ysidoro guilty, fining him 50% of the sum misapplied, with Ysidoro subsequently appealing to the Supreme Court.
### Issues:
1. Whether Ysidoro approved the diversion of goods to a public purpose different from their original allotment.
2. Whether the diverted goods were considered savings that could be allocated to other municipal expenditures.
3. Whether Ysidoro’s failure to present the municipal auditor negatively impacted his defense.
4. Validity of good faith as a defense against charges of technical malversation.
### Court’s Decision:
1. The Supreme Court found Ysidoro guilty, affirming that he diverted goods to a purpose different from that for which they were originally appropriated. The diversion violated guidelines and was deemed technical malversation.
2. The defense that the goods constituted savings was rejected, as the SFP ran throughout the year, making such an assertion premature and misaligned with procedural requirements for fund reallocation.
3. The Court dismissed concerns over not presenting the municipal auditor’s testimony, indicating it wouldn’t significantly impact the case’s outcome.
4. It was established that good faith is not a defense against technical malversation, highlighting the offense as mala prohibita, concerned with the act of diversion irrespective of intent.
### Doctrine:
This case reiterates the doctrine regarding technical malversation, emphasizing the necessity for public officials to adhere strictly to legal appropriations for public funds or property. It underscores that good faith does not exculpate an accountable public officer from the liability of diverting funds or property for purposes different than those originally intended by law or ordinance.
### Class Notes:
– **Technical Malversation (Art. 220, Revised Penal Code):** Involves (a) an accountable public officer, (b) applying public funds or property under his administration to some public use, (c) that is different from the purpose for which they were appropriated by law or ordinance.
– **Mala Prohibita Crimes:** Defined by the act’s illegality determined by law rather than the act’s inherent immorality. Demonstrates how intent or good faith is irrelevant in certain legal violations.
– **Legislative Appropriations:** The legal requirement that funds or property appropriated for specific purposes must be used exclusively for those purposes, with any reallocation requiring legislative sanction.
### Historical Background:
This case illustrates challenges in public administration and the framing of legal statutes to protect public funds against misuse. It highlights the boundaries set by the law for public officials, ensuring accountability and adherence to the specified use of public resources. This case, occurring against the backdrop of governance and public service in the Philippines, reinforces the critical balance between discretion and legal compliance in managing public goods.
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