Facts:

The case involves petitioners J.R. Nereus O. Acosta and Socorro O. Acosta against the People of the Philippines, with a decision rendered by the Second Division of the Supreme Court on November 24, 2021, regarding a Petition for Review on Certiorari filed on July 13, 2016. The petition was aimed at challenging the Sandiganbayan's Decision dated March 28, 2016, and Resolution dated June 14, 2016, concerning Criminal Case Nos. SB-09-CRM-0020 and SB-09-CRM-0021. In these cases, Socorro was convicted for violating Section 3(h) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), while both Nereus and Socorro were convicted for violation of Section 3(e) of the same act.

Nereus served as a member of the House of Representatives for the First District of Bukidnon from 1998 to 2007, overseeing funds allocated from his Priority Development Assistance Fund (PDAF) toward organizations including the Bukidnon Integrated Network of Home Industries, Inc. (BINHI) and the Bukidn

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Facts:

Background and Parties

• Petitioners J.R. Nereus O. Acosta and Socorro O. Acosta, high‐ranking public officers, are at the center of this case.
• Nereus served as a member of the House of Representatives representing the First District of Bukidnon (1998–2007).
• Socorro was the Municipal Mayor of Manolo Fortich, Bukidnon.
• They utilized the Priority Development Assistance Fund (PDAF) allocated to Nereus for funding various local projects.

Transactions Involving PDAF Funds

• BINHI (Bukidnon Integrated Network of Home Industries, Inc.)
• BINHI is a non-stock, non-profit organization formed in 1989, listing Juan C. Acosta (Nereus’ father) and Ma. Nemia O. Bornidor (Nereus’ aunt) among its incorporators.
• A solar tunnel dryer project was undertaken:
• A Memorandum of Agreement (MOA) was executed on January 9, 2001 between Nereus and Mayor Amado Noble, Sr., authorizing the appropriation of ₱2,500,000.00 for the acquisition and installation of a solar tunnel dryer for BINHI’s Talakag branch.

ii. The solar tunnel dryer was purchased by Bulkem, Inc., delivered in February 2001, received by Nemia, and later transferred by Nereus to the Municipality of Manolo Fortich.

Criminal Charges and Proceedings

• Four criminal cases were filed before the Sandiganbayan for alleged violations of R.A. No. 3019 (the Anti-Graft and Corrupt Practices Act):
• Criminal Case No. SB-09-CRM-0018: Nereus was charged with violation of Section 3(e) for allegedly transferring the solar tunnel dryer to benefit BINHI.
• Criminal Case No. SB-09-CRM-0019: Nereus (and co-accused Nemia) faced charges under Section 3(e) for authorizing the release of ₱2,500,000.00 to BINHI.
• Criminal Case No. SB-09-CRM-0020: Socorro was charged with violation of Section 3(h) for allegedly having a financial interest in the transaction involving the ₱5,500,000.00 released to BVPC.
• Criminal Case No. SB-09-CRM-0021: Both Nereus and Socorro were charged with violation of Section 3(e) for facilitating the release of the ₱5,500,000.00 to BVPC.
• Evidence and Testimonies
• The prosecution presented several witnesses (including Mayor Noble, various auditors, and experts) to testify on the factual matrix.
• For the defense, petitioners introduced witnesses and documentary evidence including the submission of the Annual Report of BVPC and other records meant to refute the allegation of undue injury and improper benefit.
• Trial Developments
• The trial proceeded with the Sandiganbayan admitting the prosecution’s evidence and, partially, the defense’s evidence (while excluding key documents, such as a certified true copy of the Annual Report of BVPC).
• Both parties filed motions for reconsideration and new trial which were denied by the Sandiganbayan before the appeal.

Rulings at the Lower Court Level

• In Criminal Case No. SB-09-CRM-0018 and SB-09-CRM-0019, Nereus (and Nemia in the latter) were acquitted due to insufficient evidence proving guilt beyond reasonable doubt.
• For Criminal Case No. SB-09-CRM-0020, Socorro was convicted for violation of Section 3(h) and sentenced to imprisonment with perpetual disqualification from public office.
• In Criminal Case No. SB-09-CRM-0021, both Nereus and Socorro were convicted for violation of Section 3(e) based on findings that they caused undue injury and conferred unwarranted benefit to BVPC through their actions.

Appeal and Arguments on Certiorari

• Petitioners argued that the prosecution failed to establish that Socorro maintained any financial or material interest in BVPC at the time the funds were released.
• They contended that the procedure for the release of PDAF funds (under DBM guidelines and the General Appropriations Act) did not require a Memorandum of Agreement (MOA) or Sangguniang Bayan approval.
• Further, they objected to the Sandiganbayan’s evidentiary rulings (notably the exclusion of the Annual Report of BVPC) and maintained that their actions were legally justified.
• The petition raised both questions of fact and law regarding the proper interpretation and application of R.A. No. 3019 and related statutes.

Supreme Court’s Intervention

• The Supreme Court, while generally not reviewing factual determinations, examined questions of law and notable factual misinterpretations or grave abuse of discretion by the Sandiganbayan—especially regarding the alleged financial interest and the requirements under the Local Government Code.
• The Court reviewed the entire process including the evidentiary record, witness testimonies, and relevant documents concerning the release of PDAF funds.

Issue:

• Whether the prosecution established beyond reasonable doubt that Nereus and Socorro had a direct or indirect financial or pecuniary interest in BVPC at the time of the PDAF fund releases.
• Whether the release of the PDAF funds to BVPC, without a formally executed MOA and Sangguniang Bayan concurrence, constitutes a violation of Section 3(e) of R.A. No. 3019.
• Whether Socorro’s actions—specifically her purported intervention in approving the disbursement of ₱5,500,000.00—amounted to having a financial interest under Section 3(h) of the Anti-Graft Law.
• Whether the evidentiary determinations (including the exclusion of the Annual Report of BVPC) by the Sandiganbayan were proper, or whether they resulted in a grave abuse of discretion and misapprehension of facts.
• Whether the legal elements of causing undue injury or conferring unwarranted benefit as required under Section 3(e) were sufficiently proved.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)