G.R. No. 90462 - Lirio vs. Court of Appeals

Joel Pancho Bigcas (Bigcas), petitioner, was charged with violation of Section 3(c) of Republic Act No. (RA) 3019 before Branch 10, Regional Trial Court (RTC), Davao City.
The respondents were the Court of Appeals (CA) and the People of the Philippines.
Bigcas filed a Petition for Certiorari under Rule 65 assailing three CA Resolutions dated May 12, 2021 (dismissing his appeal for lack of jurisdiction), March 1, 2022 (noting without action his motion for reconsideration), and October 11, 2022 (informing of entry of judgment).

Lorlene Gonzales (Lorlene) applied for an earth moving permit, requiring a Sangguniang Barangay Resolution in Lacson, Calinan.
Bigcas was a duly elected barangay kagawad and chairperson of the Council of Environment and Natural Resources of the Barangay.
Lorlene testified Bigcas volunteered to verify information at the City Hall and asked for fare money (PHP 200), which she gave believing it was customary.
The barangay denied Lorlene's application after Bigcas presented documents showing the land was in a watershed and quarrying prohibited.
The barangay chairperson denied any practice of asking money for expenses.
Bigcas reportedly tried to return the PHP 200 to Lorlene; she refused, emphasizing it was not a loan.
Lorlene filed a complaint with the Ombudsman alleging graft.
Amadeo Gonzales, Lorlene's son, corroborated Lorlene's account that Bigcas asked for money and attempted to return it.
Maria Theresa C. Paelle, barangay secretary, testified Bigcas chaired the Council and presented to the barangay the expenses incurred (PHP 200) for processing Lorlene's application.
She also witnessed Bigcas attempting to return the money which was refused; the money was kept temporarily but ultimately returned.

Bigcas testified he was surprised a resolution approving the application was already pre-signed without deliberations.
He voiced opposition during the session due to the questionable nature of the quarry application and lack of council approval.
Lorlene later insisted Bigcas assist her in expediting the process and offered fare money.
Bigcas accepted the PHP 200 as a loan only to pacify Lorlene.
Upon verification at the City Planning Office, Bigcas learned the permit could not be granted because the area was a protected watershed.
Bigcas relayed this information to Lorlene, who accused him of delaying the process and threatened to file a case.

The RTC convicted Bigcas of violating Section 3(c) of RA 3019, sentencing him to an indeterminate penalty of six years and one month to seven years and perpetual disqualification from public office.
Bigcas filed a timely notice of appeal indicating intent to appeal to the CA.

The CA instructed Bigcas to file his appeal brief.
The CA affirmed the conviction by Decision dated December 10, 2020.
The CA dismissed Bigcas's appeal for lack of jurisdiction on May 12, 2021.
Bigcas filed a motion for reconsideration invoking the equity jurisdiction and disputing the applicability of RA 10660.
The CA noted the motion without action on March 1, 2022.
The CA directed the issuance of the entry of judgment on October 11, 2022.

Bigcas seeks nullification of the CA resolutions and prays for his appeal to be decided on merits by the proper appellate court.
Bigcas claims good faith and requests relaxation of rules due to counsel error and confusion by the trial court and CA.
The Office of the Solicitor General argues the CA acted properly in dismissing the appeal as exclusive appellate jurisdiction lies with Sandiganbayan for RA 3019 violations.

Whether a Petition for Certiorari is a proper remedy against the assailed CA resolutions.
Whether there is good ground to relax procedural rules to serve the higher interest of justice.
Whether Bigcas was properly convicted of violating Section 3(c) of RA 3019 based on the facts.