The Sandiganbayan has affirmed a regional trial court’s (RTC) ruling that convicted Liquidating Officer Manuel A. Jalimao for misappropriating P1.3 million public funds of the Camarines Norte provincial government.

The RTC based in Daet found Jalimao guilty beyond reasonable doubt of violating Article 217 of the Revised Penal Code (RPC) for converting P1.3 million for his personal use in 2008.

The trial court sentenced him to a jail term ranging from six years, one month and 10 days as minimum to 10 years, two months and 21 days as maximum, and to pay a fine of P1,360,294.58. He was also barred perpetually from holding public office.

Jalimao appealed the RTC’s ruling before the Sandiganbayan.

On top of affirming the conviction, the anti-graft court increased the maximum jail term to 11 years, six months and 21 days. It also ruled that the civil liability with payment of interest should be reckoned from the finality of the judgment until it is fully paid.

In his appeal, Jalimao claimed that the RTC committed reversible error in failing to dismiss the case against him due to inordinate delay in the termination of the preliminary investigation.

He also argued against his conviction, which he claimed was wrong as the prosecution failed to prove all the elements of the crime charged.

But the Sandiganbayan said there was no inordinate delay. The records of the case show that the formal complaint was filed before the Office of the Special Prosecutor on Aug. 26, 2009, while the preliminary investigation was terminated with the filing of the criminal charge before the RTC on Sept. 16, 2010.

It also said: "The entire period of investigation covered approximately one year and one month, or almost 400 days. While the period may, at first glance, appear lengthy, this Court is not persuaded that the same was attended by vexatious, capricious, or oppressive circumstances as contemplated under prevailing jurisprudence."

At the same time, the anti-graft court found that the prosecution was able to prove the existence of all elements of malversation.

It said the evidentiary documents and testimonies of the prosecution's witnesses all established that P1,361,083.72 was received by Jalimao and remained unremitted, therefore constituting the shortage for which he was held accountable.

"Given the strength of the prosecution's documentary and testimonial evidence, and that accused-appellant Jalimao failed to present evidence or failed to satisfactorily explain the shortage, the presumption remains unrebutted. Hence, a conviction against him is warranted," the Sandiganbayan ruled.

The 42-page decision dated Feb. 24, 2026 was written by Associate Justice Lord A. Villanueva with the concurrence of Associate Justices Sarah Jane T. Fernandez and Kevin Narce B. Vivero of the court’s sixth division.