Case Digest (G.R. No. 216745-46) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Edmundo Jose T. Buencamino v. People of the Philippines and Sandiganbayan (G.R. Nos. 216745–46, November 10, 2020), petitioner Buencamino, then Municipal Mayor of San Miguel, Bulacan, was charged in two separate Informations (Criminal Cases SB-06-CRM-0419 and SB-06-CRM-0420) with violating Section 3(e) of Republic Act No. 3019 (“Anti-Graft and Corrupt Practices Act”) by “through evident bad faith” (a) imposing and collecting an unauthorized “pass way fee” of ₱1,000 per truckload from Rosemoor Mining and Development Corporation (RMDC) and (b) ordering the impounding of two of RMDC’s delivery trucks for failure to pay that fee. The Sandiganbayan, Special Fifth Division, after trial and over petitioner’s evidentiary objections, found him guilty beyond reasonable doubt in a February 18, 2015 decision and sentenced him to an indeterminate penalty of 6 years and 1 month to 8 years on each count with perpetual disqualification from public office. Petitioner moved for reconsideration Case Digest (G.R. No. 216745-46) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Edmundo Jose T. Buencamino served as Municipal Mayor of San Miguel, Bulacan (2004).
- Rosemoor Mining and Development Corporation (RMDC) operates marble quarries; Constantino A. Pascual is its President and private complainant.
- Charges and Informations
- Criminal Case No. SB-06-CRM-0419
- Allegation: Petitioner, through evident bad faith, imposed and collected a ₱1,000 “pass way” fee per RMDC truck via a private individual, Robert Tabernero, without legal sanction (no valid ordinance or resolution).
- Criminal Case No. SB-06-CRM-0420
- Allegation: Petitioner, through evident bad faith, ordered the apprehension and impounding of RMDC trucks (plate nos. PSZ-706, UEX-283) for failure to pay the same fee.
- Trial Proceedings
- Prosecution witnesses:
- Constantino A. Pascual (RMDC President) – testified about the demand and collection of fees, lack of legal basis, impounding of trucks.
- Zenaida P. Pascual, Clarissa Pascual Fernando (RMDC officers) – corroborated undue injury and operational disruption.
- Marciano T. Cruz (Municipal Treasurer) – testified on irregular official receipts and delayed remittances.
- Documentary Evidence: Official receipts, certification letters, DILG preliminary report, police blotter certificate, mayoral memorandum.
- Petitioner’s Defense:
- Denied knowledge of any voiding of the municipal resolution (Kapasiyahan 89A-055/Kautusang Bayan 029) which he believed still authorized the fee.
- Explained Tabernero’s role as job-order employee authorized for convenience to collect fees.
- Denied issuing impounding instructions and asserted all fees were remitted properly.
- Sandiganbayan Decision (Feb 18, 2015)
- Found all elements of Section 3(e), RA 3019 proven: undue injury attendant to evident bad faith and gross inexcusable negligence.
- Convicted petitioner on both counts; sentenced him to 6 years 1 month to 8 years imprisonment per count and perpetual disqualification from public office.
Issues:
- Admissibility and Sufficiency of Evidence
- Were photocopies of resolutions, DILG report, blotter certificate and other documents admissible or hearsay?
- Did the prosecution prove guilt beyond reasonable doubt?
- Accusatory Pleading vs. Conviction
- Did convicting petitioner for “gross inexcusable negligence” violate due process when Informations charged only “evident bad faith” under Section 3(e), RA 3019?
- Element of Bad Faith and Undue Injury
- Was there proof that petitioner acted with evident bad faith?
- Was undue injury to RMDC or the Government established as required?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)