2007 to 2010 - Accused's Term in Office
Dante M. De Guzman served as the City Councilor of District III, Quezon City.
Sometime in 2008 and 2009 - Accused's Term in Office
The Quezon City Government, prompted by purchase requests from De Guzman's office, entered into four separate contracts and corresponding purchase orders for various procured items (tents, kiddie raincoats/rainboots, food supplies, and sports equipment).
Anonymous Complaint Filed
The Office of the Ombudsman (Ombudsman) received an anonymous letter-complaint denouncing anomalous transactions, including ghost projects, involving certain Quezon City councilors, including De Guzman.
Formal Complaint Filed
The Field Investigation Office of the Ombudsman filed a Complaint-Affidavit against De Guzman.
Ombudsman Finds Probable Cause
The Ombudsman found probable cause for:
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Four counts of Violation of Section 3(e) of Republic Act No. 3019.
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Four counts of Falsification of Public Documents.
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Four counts of Malversation of Public Property. The corresponding 12 Informations were ordered filed with the Sandiganbayan.
Warrant of Arrest Issued
The Sandiganbayan issued a Warrant of Arrest against De Guzman.
Arraignment
De Guzman pleaded "NOT GUILTY" to the 12 Informations.
Sandiganbayan Decision
The Sandiganbayan issued its Decision:
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GUILTY of four counts of Violation of Section 3(e) of RA 3019.
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ACQUITTED of Falsification of Public Documents and Malversation of Public Property (for failure of the prosecution to prove guilt beyond reasonable doubt in those specific charges).
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Sentenced to imprisonment of six years and one month to eight years for each of the four counts, plus perpetual disqualification from public office.
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Ordered liable to pay the Quezon City Government PHP 6,411,261.01 in civil liability.
Sandiganbayan Resolution Denying MR
The Sandiganbayan issued a Resolution denying De Guzman's Motion for Reconsideration for lack of merit, affirming its April 30, 2024, Decision.
Supreme Court Decision Promulgated
The Supreme Court DISMISSED the appeal (G.R. Nos. 274863 and 275057-59) and AFFIRMED the Sandiganbayan's Decision, finding Dante M. De Guzman GUILTY beyond reasonable doubt of four counts of violation of Section 3(e) of RA 3019, committed through gross inexcusable negligence.
People v. De Guzman
G.R. Nos. 274863 and 275057-59, July 2, 2025
FIRST DIVISION
Hernando, J.
DOCTRINE:
A public officer commits a violation of Section 3 (e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) through gross inexcusable negligence when, after initiating and concluding the procurement process for public goods using official funds, he or she fails to ensure the distribution of the received items to the intended beneficiaries, resulting in the non-accountability and loss of public funds, which constitutes undue injury to the government.
FACTS:
Accused-appellant Dante M. De Guzman, a City Councilor of Quezon City from 2007 to 2010, initiated and oversaw the procurement of specific items for his constituents in District III. These procurements involved four separate contracts for 141 custom-design tents, 1,177 kiddie raincoats and rainboots, food supplies, and sports equipment, amounting to over PHP 6.4 million. The process for each transaction, including the purchase request signed by De Guzman, public bidding, award to the winning supplier, and inspection by the General Services Office (GSO), was completed, and the suppliers were subsequently paid.
The Office of the Ombudsman investigated the transactions and found that De Guzman’s staff received the procured items for distribution, and De Guzman signed distribution lists to make it appear the items were received by area coordinators for barangay distribution. However, the items were never actually distributed or received by the intended beneficiaries, and the signatures on the distribution lists were found to be falsified, indicating a cover-up for the non-distribution. The Sandiganbayan ultimately convicted De Guzman of four counts of Violation of Section 3 (e) of R.A. No. 3019 (Graft), but acquitted him of Falsification of Public Documents and Malversation of Public Property, a decision which De Guzman appealed to the Supreme Court.
ISSUE(S):
Was the Sandiganbayan correct in finding the accused-appellant guilty beyond reasonable doubt of violating Section 3 (e) of Republic Act No. 3019?
RULING:
YES. The conviction is based on Section 3 (e) of Republic Act No. 3019, which penalizes a public officer for:
(e) Causing any undue injury to any party, including the Government, or giving any private party any unwarranted benefits, advantage or preference in the discharge of his official, administrative or judicial functions through manifest partiality, evident bad faith or gross inexcusable negligence.
This Court rules that accused-appellant, as then City Councilor of Quezon City, violated Section 3 (e) of Republic Act No. 3019 when he caused the purchase of 141 custom-design tents, 1,177 kiddie raincoats, 1,177 rainboots, food supplies, and sports equipment, received the procured items, then failed to distribute them to the intended beneficiaries of District III, Quezon City. Consequently, accused-appellant defrauded and caused undue injury to the Quezon City Government.
[Accused-appellant]’s failure to cause the distribution of the subject items to the different barangays of District III, Quezon City was attended by gross inexcusable negligence. Although he was not expected to personally distribute each of the subject items to the intended beneficiaries, he was duty-bound to ensure that the same were distributed because he caused the procurement of the items for the purpose of distributing them to his constituents. [Accused-appellant]’s failure to cause the distribution of the subject items and seeming lack of concern about them shows his indifference to consequences as other persons may be affected.
Consequently, the Quezon City Government suffered undue injury amounting to PHP 6,411,261.01, representing the amounts paid by the Quezon City Government for the procured items. Taken altogether, the prosecution proved beyond a reasonable doubt all the elements of violation of Section 3 (e) of Republic Act No. 3019.