AMELIA C. ZOLETA v. THE HONORABLE SANDIGNBAYAN, G.R. No.

185224
July 29, 2015
Doctrine: Local Government officials become accountable public officers
either (1) because of the nature of their functions; or (2) on account of their
participation in the use or application of public funds.
Facts: A complaint was filed against the LGU officials of the Province of
Saranggani charging them with Malversaation of Public Funds by Falsification
of Public Documents, before the Sandiganbayan.
The case stemmed from the irregularities discovered by the Special Audit
Team that a financial assistance had been sought by an association called
Women in Progress, chaired by herein petitioner, when in fact and in truth no
financial assistance has been requested and received by the association.
Issue: Whether or not the Sandiganbayan correctly held the petitioners liable
for the misappropriation of public funds?
Ruling: All the accused are all public officers. The funds misappropriated are
public funds in character, as the y were funds belonging to the Province of
Saranggani.
The local government officials become accountable public officers either
because of the nature of their functions or on account of their participation in
the use or application of the public funds. Local government official
accountability for public funds or property is expounded under section 340 of
the LGC.
Moreover, as a standard procedure, any disbursement and release of public
funds require the approval of the Vice Governor and the Provincial Accountant.
Thus, in their capacities as such, they had control and responsibility over the
subject fund.