FACTS:

Petitioner Hermenegildo M. Magsuci, the Regional Director of the Bureau of Fisheries and Aquatic Resources (BFAR), and private person Jaime B. Ancla were charged with conspiring to issue and falsify a Certificate of Completion and Accomplishment Report for a construction project. The fraudulent documents allowed them to receive over P400,000 through a Disbursement Voucher and Treasury Checks. Magsuci pleaded not guilty, surrendered voluntarily, and Ancla absconded. The Sandiganbayan found Magsuci guilty after establishing that BFAR and Dexter Construction had a contract, Magsuci relied on the Accomplishment Report and Certification, and directed the issuance of the voucher and signed the checks.

ISSUES:

1. Whether criminal responsibility may be incurred by a head of office who relied on an act of his subordinate in the discharge of his official duties.

RULING:

1. The Court did not explicitly provide a ruling on this particular issue. However, it mentioned that there is no inflexible rule on whether criminal responsibility may be incurred by a head of office who relied on an act of his subordinate. This suggests that the Court recognized that the determination of criminal responsibility in such cases should be based on the specific facts and circumstances of each case.

PRINCIPLES:

• The determination of criminal responsibility of a head of office who relied on an act of his subordinate in the discharge of his official duties may vary depending on the specific facts and circumstances of each case.