MANILA, Philippines — The Supreme Court (SC) First Division has affirmed the conviction of former Quezon City Councilor Dante Manzano De Guzman for four counts of violating Section 3(e) of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019). The ruling, promulgated on July 2, 2025, confirmed that De Guzman acted with gross inexcusable negligence, causing undue injury to the Quezon City Government amounting to PHP 6,411,261.01. The decision was penned by Associate Justice Ramon Paul L. Hernando.
Procurement and Missing Supplies
De Guzman served as City Councilor for District III, Quezon City, from 2007 to 2010. The case centered on four separate contracts initiated by his office between 2008 and 2009 for the procurement of various goods, including 141 custom-design tents, 1,177 kiddie raincoats and rainboots, food supplies, and sports equipment. The investigation by the Office of the Ombudsman revealed that while public bidding was conducted, the contracts were awarded, and the suppliers were paid, the procured items were never actually distributed to the intended barangay beneficiaries of District III.
The Ombudsman found that De Guzman’s staff received the items, and he signed distribution lists purporting to show the items were handed over to “area coordinators” for various barangays. However, subsequent findings proved that the individuals listed were not the legitimate coordinators, and the items could not be located or accounted for after they were turned over to De Guzman’s custody. The Sandiganbayan, in its April 30, 2024 Decision, found De Guzman guilty of graft but acquitted him of Falsification of Public Documents and Malversation of Public Property.
Gross Negligence and Undue Injury
The core legal issue addressed by the Supreme Court was whether the prosecution had proven all elements necessary to sustain a conviction for graft under Section 3(e) of RA 3019, specifically focusing on the element of “gross inexcusable negligence” and the resulting “undue injury” to the government. De Guzman, in his appeal, contended that the Sandiganbayan’s factual findings were erroneous, including the authenticity of his signature on procurement documents.
The Ruling
The Supreme Court dismissed De Guzman’s appeal, sustaining the factual findings of the Sandiganbayan. The Court found that all elements of the offense were proven beyond reasonable doubt. It affirmed that De Guzman, as a public officer, discharged official functions related to the procurement and receipt of the items.
The Court held that De Guzman acted with gross inexcusable negligence. The sheer failure to cause the distribution of millions of pesos worth of supplies, coupled with his “seeming lack of concern,” amounted to a serious breach of duty and an “indifference to consequences.” The Court emphasized that while he was not expected to personally distribute every item, he had the duty, as the head of the office who caused the procurement, to ensure the items reached the intended beneficiaries. This failure directly resulted in undue injury to the Quezon City Government, which paid the full amount of PHP 6,411,261.01 for items that were never used for the public benefit.
The SC, therefore, AFFIRMED the Sandiganbayan’s penalty: imprisonment of six years and one month, as minimum, to eight years, as maximum, for each of the four counts, along with perpetual disqualification from public office, and payment of the civil liability of PHP 6,411,261.01 plus interest.