Case Digest (G.R. No. 57937)
Facts:
The case involves Wilfredo R. Antonio as the petitioner and the Sandiganbayan (2nd Division) as the respondent. The events transpired on October 19, 1979, in Baguio City, Philippines. Wilfredo Antonio, along with Manuel Caoili and Teofilo Tinaza, Jr., were charged with violating the Anti-Graft and Corrupt Practices Act (R.A. No. 3019, as amended) for their involvement in a scheme to demand and accept "grease money" from Mrs. Edarlina de Guzman. The prosecution alleged that the three conspired to receive a sum of P800.00 from de Guzman to facilitate the issuance of a building permit for her house, which had been halted due to the absence of the required permit.
During the trial, de Guzman testified that her construction was stopped by city authorities, including Tinaza, who demanded P2,700.00 for the issuance of a permit. After negotiations, she was instructed to follow up with Antonio. On the day of the incident, de Guzman met with Antonio, who called Tinaza, and...
Case Digest (G.R. No. 57937)
Facts:
Parties Involved:
- Petitioner: Wilfredo R. Antonio, a Civil Engineer in the Ministry of Public Works, Baguio City.
- Respondent: Sandiganbayan (2nd Division).
- Co-Accused: Teofilo Tinaza, Jr. (Civil Engineer in the Office of the City Engineer, Baguio City) and Manuel Caoili (Supervising Civil Engineer in the Ministry of Public Works, Benguet Engineering District).
Charges:
- The accused were charged with violating Section 3(c) of the Anti-Graft and Corrupt Practices Act (R.A. No. 3019, as amended) for demanding and receiving "grease money" (P800.00) from Mrs. Edarlina de Guzman in exchange for the issuance of a building permit.
Incident Details:
- Mrs. Edarlina de Guzman began constructing her house in March 1979 but was stopped by city authorities, including Tinaza, for lack of a building permit.
- Tinaza and his companions initially demanded P2,700.00 for the issuance of the permit, which De Guzman paid.
- On October 19, 1979, De Guzman met with Antonio, Tinaza, and Caoili to follow up on her application. Tinaza demanded P1,000.00, but De Guzman only had P800.00, which she handed over to Tinaza.
- The Philippine Constabulary (PC) was involved in an entrapment operation, and marked bills were used to catch the accused in the act.
Trial and Conviction:
- The Sandiganbayan found all three accused guilty of violating R.A. No. 3019, sentencing them to imprisonment, perpetual disqualification from public office, and other penalties.
- Antonio filed a motion for reconsideration, which was denied, leading to the filing of the instant petition.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Conspiracy:
- Conspiracy exists when two or more persons agree to commit a felony and decide to carry it out. The agreement need not be explicit; it can be inferred from the conduct of the accused before, during, and after the crime.
- In this case, the acts of Tinaza, Antonio, and Caoili demonstrated a concerted effort to demand and receive "grease money" from De Guzman, indicating a conspiracy.
Liability of Co-Conspirators:
- Once conspiracy is established, each conspirator is liable for the acts of the others in furtherance of the conspiracy, even if they did not personally perform every act constituting the crime.
- Antonio's acceptance of part of the bribe money, knowing it came from De Guzman, and his participation in the discussions about the building permit, were sufficient to hold him liable as a principal.
Violation of R.A. No. 3019:
- The Court found that the elements of Section 3(c) of R.A. No. 3019 were met, as the accused, being public officers, directly or indirectly received pecuniary benefits in connection with the issuance of a government permit.