Case Digest (G.R. No. 81563) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Amado C. Arias v. The Sandiganbayan (G.R. No. 81563) and Cresencio D. Data v. The Sandiganbayan (G.R. No. 82512), both decided December 19, 1989, petitioners Amado C. Arias, then Auditor of the Bureau of Public Works’ Rizal Engineering District in Pasig, and Cresencio D. Data, then District Engineer of the same office, were charged before the Sandiganbayan in SB Criminal Case No. 2010 with violating Section 3(e) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act). Along with four co-accused officials and Natividad C. Gutierrez (attorney-in-fact of landowner Benjamin P. Agleham), they were accused of conspiring to cause undue injury to the Government by overpricing the negotiated purchase of 19,004 square meters of land in Rosario, Pasig for the Mangahan Floodway Project. The municipal assessor had declared the property at P5.00 per square meter in 1978 tax declarations, yet supporting papers submitted to the Government—xerox copies of tax declarations, certifi Case Digest (G.R. No. 81563) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Project
- In 1975 the Bureau of Public Works launched the Mangahan Floodway Project to alleviate flooding in Marikina and Pasig.
- The Pasig Engineering District, led by District Engineer Cresencio D. Data, formed a committee to negotiate and acquire right-of-way lands through direct purchase.
- The Agleham Property Acquisition
- Attorney-in-fact Natividad C. Gutierrez submitted falsified documents—tax declarations, certificates, technical descriptions—misclassifying a 19,004 m² riceland in Pasig as residential and valuing it at ₱80/m².
- District Engineer Data signed the deed of sale (April 20, 1978) transferring title to the Government; Auditor Amado C. Arias pre-audited and approved a voucher for ₱1,520,320 on October 23, 1978.
- A later investigation uncovered multiple forgeries: tampered tax declarations (Exhs. B, K), false certifications (Exhs. J, D, E), and a forged sworn statement on market value (Exh. Z).
- Procedural History
- The Sandiganbayan convicted Arias, Data, Gutierrez, and others under RA 3019, sec. 3(e), sentencing each to 3–6 years, perpetual disqualification, and joint indemnification.
- Arias and Data appealed to the Supreme Court; the Solicitor General filed a consolidated manifestation recommending acquittal for lack of proof and absence of undue injury.
Issues:
- Conspiracy and Participation
- Was there sufficient proof that Arias and Data knowingly conspired with co-accused to defraud the Government?
- Did the petitioners have personal, deliberate involvement in planning or executing the fraudulent scheme?
- Undue Injury and Overpricing
- Did the negotiated purchase price of ₱80/m² cause “undue injury” to the Government?
- Is the municipal assessor’s tax declaration value (₱5/m²) the correct benchmark for criminal liability on overpricing?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)