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AMADO C. ARIAS v. SANDIGANBAYAN

This case has been cited 22 times or more.

	GR No. 197953 2015-08-05	PEOPLE v. SANDIGANBAYAN BRION, J.
To support this theory, Mayor Saludaga invoked the case of Magsuci v. Sandiganbayan[18] which supposedly held that when the infraction consists in the reliance in good faith, albeit misplaced, by a head of office on a subordinate upon whom the primary responsibility rests, absent a clear case of conspiracy, the Arias doctrine[19] must be upheld.
	GR No. 157838 2012-02-07	CANDELARIO L. VERZOSA v. GUILLERMO N. CARAGUE VILLARAMA, JR., J.
Moreover, the mere fact that petitioner signed the vouchers and other documents for the processing of the purchase after the winning bidder has been chosen does not per se constitute bad faith on his part. Notably, petitioner's signature was given as final recommending/approving authority only after the entire bidding process was conducted. He cannot, therefore, be faulted for relying and depending, to a reasonable extent, on the integrity and performance of duty by the PBAC, as well as the Board of Administrators, which acted on the documents. By analogy, this Court's ruling in Arias v. Sandiganbayan[31] is instructive: x x x All heads of offices have to rely to a reasonable extent on their subordinates and on the good faith of those who prepare bids, purchase supplies, or enter into negotiations. If a department secretary entertains important visitors, the auditor is not ordinarily expected to call the restaurant about the amount of the bill, question each guest whether he was present at the luncheon, inquire whether the correct amount of food was served, and otherwise personally look into the reimbursement voucher's accuracy, propriety, and sufficiency. There has to be some added reason why he should examine each voucher in such detail. Any executive head of even small government agencies or commissions can attest to the volume of papers that must be signed. There are hundreds of documents, letters, memoranda, vouchers, and supporting papers that routinely pass through his hands. The number in bigger offices or departments is even more appalling.
	GR No. 154042 2011-04-11	JOSE T. TUBOLA v. SANDIGANBAYAN CARPIO MORALES, J.
According to petitioner, he being the superior of Valeria, he had to rely on her honesty and competence in the performance of her duties. He cites Arias v. Sandiganbayan,[18] which ruled that a head of office is not required to examine every single detail of any transaction from its inception until it is finally approved, to deem it no longer necessary for him to examine all the details each time a remittance of the fees was made.
	GR Nos. 182539-40 2011-02-21	ANTONIO Y. DE JESUS v. SANDIGANBAYAN-FOURTH DIVISION ABAD, J.
The accused local officials point out, citing Arias v. Sandiganbayan,[13] that "heads of offices have to rely to a reasonable extent on their subordinates and on the good faith of those who prepare bids, purchase supplies, or enter into negotiations." But the documents and other circumstances of these cases negate reliance on the competence and good faith of subordinates. First, the accused local officials knew or could have known that the winning supplier was the accused mayor's son. Second, the accused local officials signed the documents both in their official capacities and as witnesses evidently to avoid, as stated above, exposing the deal to other eyes. And third, the rejected suppliers did not sign the quotations they supposedly submitted. Indeed, the space for their signatures was just above the space where the accused local officials signed.[14]
	GR Nos. 175045-46 2010-03-03	ENGR. RICARDO L. SANTILLANO v. PEOPLE VELASCO JR., J.
In petitioner's case, the finding of conspiracy is not unfounded. In all three criminal cases, the prosecution was able to establish that Ecleo, Jr. and Navarra approved of overpayments made to Santillano. The Sandiganbayan did not give much weight to their weak defense of alibi. What is more, it correctly ruled that the doctrine in Arias v. Sandiganbayan[22] could not be used by Ecleo, Jr. to escape liability, as the documents he had to approve were not so voluminous so as to preclude him from studying each one carefully. On the contrary, if he had the best interest of his constituents in mind, he should have examined all the project documents, as a good deal of taxpayers' money was involved. Navarra's alibi was also not enough to acquit her. She was not precluded from signing the documents relating to the subject projects while she was on leave. She also did not establish any proof that her signatures were forged. Worse, both Ecleo, Jr. and Navarra were parties to an agreement that approved disbursement of funds for a bogus municipal guest house and they could not come up with a plausible justification for such a gaffe.
	AM No. 2007-02-SC 2010-02-10	RE: COMPLAINT OF JUDGE ROWENA NIEVES A. TAN FOR LATE REMITTANCE BY SUPREME COURT OF HER TERMINAL LEAVE PAY TO GSIS TO APPLY FOR PAYMENT OF HER SALARY LOAN TO SAID AGENCY. CARPIO MORALES, J.
There is no showing that the supporting documents attached to the journal entry voucher had palpable or patent defects to call for the non-recording of said voucher in the accounting books. Laxity cannot thus be ascribed to Minerva. Given her position, she cannot be expected to personally examine every single detail of all the transactions passing through her desk. Arias v. Sandiganbayan[15] teaches: ...All heads of offices have to rely to a reasonable extent on their subordinates and on the good faith of those who prepare bids, purchase supplies or enter into negotiations. x x x. There has to be some added reason why he should examine each voucher in such detail. Any executive head of even small government agencies or commissions can attest to the volume of papers that must be signed. There are hundreds of documents, letters, memodanda, vouchers and supporting papers that routinely pass through his hands. The number in bigger offices or departments is even more appalling.
	GR No. 154117 2009-10-02	ERNESTO FRANCISCO v. OMBUDSMAN ANIANO A. DESIERTO LEONARDO-DE CASTRO, J.
Private respondent Vigilar avers that he only exercised administrative supervision over the TRB under the provisions of Sec. 38, Ch. 7, Book IV of the Revised Administrative Code of 1987; and that he acted in good faith, relying on the recommendation of the technical officers of the TRB, and cites Arias v. Sandiganbayan[76] to support this averment.
	GR Nos. 181999 & 182001-04 2009-09-02	OFELIA C. CAUNAN v. PEOPLE NACHURA, J.
Aggrieved, petitioners and the other accused appealed to the COA which eventually denied the appeal. Surprisingly, on motion for reconsideration, the COA excluded petitioner Marquez from liability for the disallowances based on our rulings in Arias v. Sandiganbayan[8] and Magsuci v. Sandiganbayan.[9]
	GR No. 177430 2009-07-14	RENE M. FRANCISCO v. PEOPLE CHICO-NAZARIO, J.
Ojeda cites Macadangdang v. Sandiganbayan,[58] Arias v. Sandiganbayan,[59] De la Peña v. Sandiganbayan[60] and Magsuci v. Sandiganbayan[61] to justify his reliance on the recommendation of his subordinate and on the "yellow" classification of the ASYCUDA (Automated System for Customs Data) Program.
	GR No. 166658 2008-04-30	EUSTAQUIO B. CESA v. OFFICE OF OMBUDSMAN QUISUMBING, J.
SO ORDERED.[12] The Court of Appeals dismissed Cesa's gripe that there was lack of due process as the Ombudsman can undertake criminal or administrative investigations sans any complaint. It ruled that procedural infirmities, if any, were cured when petitioner was present during the preliminary conference, submitted his counter-affidavit and supplemental counter-affidavit, actively participated in the proceedings by cross-examining witnesses, and filed a motion for reconsideration. It found Cesa negligent for tolerating the illegal practices on cash advances because he approved the paymasters' requests for cash advances based on pieces of paper without any particulars and without diligent supervision over them. The Court of Appeals ruled that the Arias ruling[13] where this Court held that heads of offices have to rely to a reasonable extent on their subordinates, is inapplicable to this case for it had not been alleged that Cesa conspired with Badana. What was proven was that his negligence in carrying out his duties as city treasurer contributed to giving Badana the opportunity to malverse more than P18 million in public funds.
	GR NO. 150091 2007-04-02	YOLANDA O. ALFONSO v. OFFICE OF PRESIDENT CARPIO MORALES, J.
Unlike in Arias v. Sandiganbayan,[46] upon which petitioner relies for jurisprudential support, petitioner's foreknowledge of facts and circumstances that suggested an irregularity constituted added reason[47] for her to exercise a greater degree of circumspection before signing and issuing the titles.
	GR NO. 169029 2006-08-22	OFFICE OF OMBUDSMAN v. ROGELIO Q. TONGSON CALLEJO, SR., J.
Petitioner claims that the doctrine in Arias v. Sandiganbayan[48] could not be invoked by respondents, as they rest on different facts. Petitioner's findings must likewise be given greater weight and accorded full respect and credit.
	GR NOS. 169727-28 2006-08-18	BRIG. GEN. JOSE S. RAMISCAL v. SANDIGANBAYAN CALLEJO, SR., J.
The matter was further looked into by a panel of Ombudsman Investigators, which issued on March 30, 2001 a Joint Resolution[4] finding probable cause to file the corresponding Informations for 148 counts of violation of Article 315, in relation to Article 171, paragraph 4 of the Revised Penal Code, and Section 3 (e) of R.A. No. 3019 against Meinrado Bello and Atty. Manuel Satuito. However, it was likewise recommended that the complaint against petitioner be dismissed, without prejudice to a thorough fact-finding investigation on his liability in light of this Court's ruling in Arias v. Sandiganbayan.[5]
	GR NO. 161077 2006-03-10	SAMSON B. BEDRUZ v. OFFICE OF OMBUDSMAN CARPIO MORALES, J.
Petitioners argue that as the Suarez spouses have a title and tax declaration in their name over the lot, they are entitled to its possession and may exclude any stranger from its enjoyment. [20] Additionally, they argue that they relied on the subordinate officers who processed the application before it reached them for approval, hence, they acted in good faith and, following the doctrine laid down in Arias v. Sandiganbayan, [21] they are not liable.
	GR NO. 154665 2006-02-10	MANUEL LEYCANO v. COA CARPIO MORALES, J.
We can, in retrospect, argue that Arias should have probed records, inspected documents, received procedures, and questioned persons. It is doubtful if any auditor for a fairly sized office could personally do all these things in all vouchers presented for his signature. The Court would be asking for the impossible. All heads of offices have to rely to a reasonable extent on their subordinates and on the good faith of those who prepare bids, purchase supplies, or enter into negotiations. If a department secretary entertains important visitors, the auditor is not ordinarily expected to call the restaurant about the amount of the bill, question each guest whether he was present at the luncheon, inquire whether the correct amount of food was served, and otherwise personally look into the reimbursement voucher's accuracy, propriety, and sufficiency. There has to be some added reason why he should examine each voucher in such detail. Any executive head of even small government agencies or commissions can attest to the volume of papers that must be signed. There are hundreds of documents, letters, memoranda, vouchers, and supporting papers that routinely pass through his hands. The number in bigger offices or departments is even more appalling.[8] (Emphasis and underscoring supplied)
	GR NO. 152188 2005-08-08	FLORENTINO R.* BRUCAL v. ANIANO A. DESIERTO QUISUMBING, J.
Petitioner Brucal contends that he cannot be held liable for dishonesty emphasizing that he was signatory solely on the Statement of Time Elapsed, a document which pertains to the original contract time, date of effectivity of contract, contract amount, total calendar days elapsed to date, percentage of time elapsed, percentage of work accomplished and slippage.[27] It had nothing to do with the materials used in the project nor the manner of its construction in accordance with the approved plans and specifications as charged.[28] Petitioner Cruz, for his part, contends that he cannot be faulted for relying on Engr. Razo's certification that the materials used in the project had been tested and had passed all the requirements.[29] As enunciated in Sistoza v. Desierto[30] and Arias v. Sandiganbayan,[31] Cruz avers that as head of office, he can, to a reasonable extent rely on his subordinate.
	GR No. 161629 2005-07-29	ATTY. RONALDO P. LEDESMA v. CA YNARES-SANTIAGO, J.
In Arias v. Sandiganbayan,[15] we stated that all heads of offices have to rely to a reasonable extent on their subordinates. Practicality and efficiency in the conduct of government business dictate that the gritty details be sifted and reviewed by the time it reaches the final approving authority. In the case at bar, it is not unreasonable for the BOC to rely on the evaluation and recommendation of the BSI as it cannot be expected to review every detail of each application transmitted for its approval. Petitioner being the Chairman of the First Division of the BSI has direct supervision over its proceedings. Thus, he cannot feign ignorance or good faith when the irregularities in the TRV extension applications are so patently clear on its face. He is principally accountable for certifying the regularity and propriety of the applications which he knew were defective.
	GR No. 164921 2005-07-08	ROSENDO H. ESCARA v. PEOPLE YNARES-SANTIAGO, J.
The facts obtaining in the cases of Arias v. Sandiganbayan[38] and Magsuci v. Sandiganbayan[39] are not analogous to this case.
	GR No. 152188 2005-07-08	FLORENTINO R.* BRUCAL v. ANIANO A. DESIERTO QUISUMBING, J.
Petitioner Brucal contends that he cannot be held liable for dishonesty emphasizing that he was signatory solely on the Statement of Time Elapsed, a document which pertains to the original contract time, date of effectivity of contract, contract amount, total calendar days elapsed to date, percentage of time elapsed, percentage of work accomplished and slippage.[27] It had nothing to do with the materials used in the project nor the manner of its construction in accordance with the approved plans and specifications as charged.[28] Petitioner Cruz, for his part, contends that he cannot be faulted for relying on Engr. Razo's certification that the materials used in the project had been tested and had passed all the requirements.[29] As enunciated in Sistoza v. Desierto[30] and Arias v. Sandiganbayan,[31] Cruz avers that as head of office, he can, to a reasonable extent rely on his subordinate.
	GR NO. 134509 2005-04-12	VENANCIO R. NAVA v. NATIONAL BUREAU OF INVESTIGATION TINGA, J.
Nava filed before the Second Division of the Sandiganbayan a Motion for Reinvestigation[19] which was granted in a Resolution dated 22 September 1997.[20] On 4 May 1998, Special Prosecution Officer Manuel A. Corpuz (hereinafter, Special Prosecutor) recommended the dismissal of the charges against Nava and Granada for insufficiency of evidence. This recommendation was, however, disapproved by the Ombudsman.[21] Hence, the instant Petition in which Nava contends that the Ombudsman gravely erred or was "manifestly mistaken" in disapproving the recommendation of dismissal of the case against him, which disapproval, he further avers, is based on an erroneous conclusion drawn from "undisputed" facts which assumes the nature of a question of law reviewable by this Honorable Court. Petitioner cites the cases of Arias v. Sandiganbayan[22] and Magsuci v. Sandiganbayan[23] to support his stance that the case against him should have been ordered dismissed.[24]
	GR No. 147333 2004-08-12	ROSALIA* M. DUGAYON v. PEOPLE QUISUMBING, J.
On the issue of conspiracy, petitioner relies on Magsuci v. Sandiganbayan,[15] which cited Arias v. Sandiganbayan,[16] as precedent to prove the high improbability of her conspiring with her co-accused. She quotes,
	GR No. 154499 2004-02-27	ALBERTO V. REYES v. RURAL BANK OF SAN MIGUEL TINGA, J.
It is noteworthy again that petitioners' alleged role in the disclosure of information is not anchored on any concrete piece of evidence. That explains the RBSMI's effort to cast liability vicariously on the petitioners by a superficial resort to the principle of command responsibility which this Court did not reject. But neither the principle itself which is an accepted notion in military or police structural dynamics or its counterpart of respondent superior in the law on quasi-delicts[11] would be relevant in this case, involving as it does the actual performance in office of the petitioners and given the fact that petitioners are high ranking officers of the country's central monetary authority. Indeed, as such officers, petitioners cannot be expected to monitor the activities of their subalterns. In Arias v. Sandiganbayan,[12] this Court held that all heads of offices have to rely to a reasonable extent on the good faith of their subordinates. The case specifically involved the liability of the head of office in the preparation of bids, purchase of supplies and contract negotiations done by his subordinates. In the same fashion, petitioners in this case owing to their high ranks cannot be expected to acquaint themselves with such minutiae as the flow of files and documents which leave their desks. Myriad details such as those are, by office practice, left to subalterns and minor employees. Delegation of function is part of sound management.