G.R. No. L-21975 - Ramos vs. Ardant Trading Corp.

On March 15, 1978, Marciana Vda. De Coronado (Visitacion's late mother) and the Municipality of Nagcarlan, Laguna, represented by then Municipal Mayor Crisostomo P. Manalang, entered into a lease contract.
The lease was for a lot and store at Poblacion, Nagcarlan, Laguna for 20 years (March 15, 1978 to March 15, 1998) with an option to extend another 20 years.
The contract allowed the building of a firewall and preferential rights upon modification of the public market.
After De Coronado’s death in 1984, Visitacion Bombasi continued to operate the store and secured yearly Mayor’s permits until January 1993.

In 1986, a fire razed the public market; Visitacion requested inspection on May 15, 1986.
District Engineer Marcelino B. Gorospe found Visitacion’s store intact and strong, a finding contested by the Municipality.
The store continued operations until October 15, 1993.

On September 1, 1993, Mayor Demetrio T. Comendador directed Visitacion to demolish the store within 5 days based on Sangguniang Bayan Resolution Nos. 156 (August 30, 1993) and 183 (October 11, 1993), and a memorandum from the Assistant Provincial Prosecutor.
Resolutions authorized the Mayor to demolish structures obstructing construction of a new municipal market and to file unlawful detainer cases if resisted.
Visitacion replied on September 3, 1993, asserting the binding lease contract, willingness to vacate if given equivalent space, and consent to unlawful detainer case if negotiations failed.
Assistant Provincial Prosecutor sent a letter on September 15, 1993, ordering Visitacion to vacate within 15 days or face court action.
On October 14, 1993, Municipal Administrator Paulino S. Asilo, Jr. informed Visitacion of impending demolition; she responded denying legal authority for demolition without court order and threatened legal actions.

Despite objections, on October 15, 1993, Mayor Comendador ordered demolition supervised by Asilo and Angeles.
Engineer Winston Cabrega estimated damages at P437,900.00.
On August 19, 1994, the Spouses Bombasi filed a civil case for damages and preliminary injunction against the Municipality, Mayor Comendador, Asilo, and Angeles.
The complaint was amended to include occupants of the area as defendants (Spouses Alida and Teddy Coroza; Spouses Benita and Isagani Coronado).
On an unspecified date, criminal complaint was filed against Comendador, Asilo, and Angeles for violation of Section 3(e) of RA 3019 (Anti-Graft and Corrupt Practices Act).

Information was filed on February 22, 1996. Arraignment resulted in not guilty pleas.
Civil and criminal cases were consolidated pursuant to PD 1606.
Angeles died on November 16, 1997; case against him was dismissed without objection.
Mayor Comendador died on September 17, 2002; his counsel notified the court.
On April 28, 2003, Sandiganbayan found Comendador and Asilo guilty beyond reasonable doubt of violating RA 3019 Sec. 3(e), sentenced them and ordered them, along with the Municipality, to pay damages to Spouses Bombasi.
Cases against occupant spouses were dismissed.
Motions for reconsideration filed by Asilo and Comendador’s counsel were denied or granted in part; criminal liability of Mayor Comendador was extinguished by death, but civil liability survived.

Petitioners, Asilo and Victoria Bueta Vda. De Comendador (representing late Mayor Comendador) filed appeals.
Issues raised included good faith defense, extinction of liability by death, and sufficiency of damages awarded.

Whether petitioner public officials committed violation of Section 3(e) of RA 3019 by causing undue injury through demolition without legal authority.
Whether good faith in complying with superior’s orders negates liability under RA 3019.
Whether the death of Mayor Comendador extinguished his civil liability.
Whether the damages awarded to Spouses Bombasi were substantiated and proper in amount.
Whether demolition of the store without court order violated the Spouses Bombasi’s right to due process.