Arias v. Sandiganbayan, GR No.

81563, December 19, 1989

Facts:
Arias (District Engineer) and Data (Chief Auditor), officials of the Province of Rizal were found
guilty by the Sandiganbayan (SB) together with their subordinates and a private citizen (seller of
land) for “having caused injury to & damage to the Republic of the Philippines” in connection
with scandalous overpricing of land purchased by the Government as right of way for a floodway
project, by allowing & approving the illegal disbursement & expenditure of public funds. The
decision of SB insofar as Arias & Data are concerned was overturned by the SC based on the
reasoning of reliance of good faith on subordinates.

Issue:
Whether or not SB petitioners ARIAS and DATA are guilty as co-conspirators in the conspiracy
to cause injury to the Government through the irregular disbursement and expenditure of public
funds.

Ruling:
No. There should be other grounds than the mere signature or approval appearing on a voucher
to sustain a conspiracy charge and conviction. SB decision SET ASIDE insofar as it convicts
and sentences petitioners Arias & Data. They are both acquitted on grounds of reasonable
doubt. Inadequacy of evidence is not sufficient to warrant a conviction.