Matobato, Sr. v. People, G.R. Nos. 229265 & 229624 [February 15, 2022]

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MATOBATO, SR. V. PEOPLE

 G.R. Nos. 229265 & 229624, [February 15, 2022]

FIRST DIVISION, LOPEZ, M.V

 

Law on Public Officers; Three-fold Liability rule; Sandiganbayan; Public Funds; Municipal Treasurer 

Under the "threefold liability rule," the wrongful acts or omissions of public officers may give rise to civil, criminal, and administrative liabilities. The dismissal of the criminal action does not extinguish the civil liability if (1) the acquittal is based on reasonable doubt; (2) the court declares that the liability is civil only; and (3) that the civil liability does not arise from the crime of which the accused was acquitted. The quantum of proof          to establish civil liability is preponderance of evidence only. Corollarily, public officers could still be held civilly liable to reimburse the injured party notwithstanding their acquittal.

 

The Municipality of Pantukan authorized its Treasurer, Silvino Matobato, Sr., to transfer funds to Davao Cooperative Bank (DCB) based on a resolution. DCB suffered insolvency, and the municipality couldn't withdraw the funds. The Commission on Audit (COA) recommended criminal and administrative charges. Silvino, along with Sangguniang Bayan members Walter Bucao and Cirila Engbino, faced charges for violating RA No. 3019. The Sandiganbayan acquitted them due to insufficient evidence for criminal liability but found them civilly liable for the municipality's unrecovered funds.

 

Whether Silvino, Walter, and Cirila can be held civilly liable despite their acquittal on criminal charges.

YES. The court affirms the Sandiganbayan's decision, holding Silvino, Walter, and Cirila civilly and solidarily liable. Their acquittal on criminal charges doesn't extinguish civil liability, which the law requires only preponderance of evidence. It pertains to evidence which is more convincing to the court as worthy of belief than that which is offered in opposition thereto. Here, the required quantum of proof was met to sustain the Sandiganbayan's findings on the civil liability of Silvino, Walter, and Cirila.

Silvino's negligence in depositing funds without due diligence and the others' reliance on verbal assurances without further scrutiny breached their duties. Silvino did not establish any precautionary or contingent measure to protect the financial interests of the Municipality of Pantukan from the whiplash of DCB's insolvency. It is likewise the Municipal Treasurer's duty to ensure that these funds are safe guarded, but Silvino failed to comply with these duties. On the part of Walter and Cirila, as Sangguniang Bayan members, they failed to require and examined the audited financial statements of DCB. Their negligence paves to their indispensable participations in the transfer of funds to DCB.

On this point, the Court reminds that public funds, like public office, are founded on public trust. How the public funds are managed and how they are safely kept reflect on the ability of the government to keep inviolate its fiduciary duty to the people. Therefore, Silvino, Walter, and Cirila are held civilly and solidarily liable to indemnify the Municipality of Pantukan.

 

 

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