Case Digest (G.R. No. 122058)
Facts:
The case involves petitioners Ignacio R. Bunye, Jaime R. Fresnedi, Carlos G. Tensuan, Roman E. Niefes, Roger C. Smith, Rufino B. Joaquin, Nolasco L. Diaz, and Rufino Ibe, who were public officers in the Municipality of Muntinlupa, Metro Manila. The events leading to the case began in August 1988 when the petitioners enacted Kapasiyahan Bilang 45, which led to the forcible takeover of the New Public Market in Alabang, Muntinlupa. This action was taken despite an existing lease contract between the Municipality of Muntinlupa and the Kilusang Bayan sa Paglilingkod ng mga Magtitinda sa Bagong Pamilihang Bayan ng Muntinlupa, Inc. (KBMBPM), which had been executed on September 2, 1985, for a term of 25 years, renewable for another 25 years. The lease contract stipulated a monthly rental of P35,000.00, which was significantly lower than the market's income. The Commission on Audit (COA) and the Metro Manila Commission (MMC) had previously advised the petitioners to take legal st...
Case Digest (G.R. No. 122058)
Facts:
Background of the Case
The case involves petitioners Ignacio R. Bunye, Jaime R. Fresnedi, Carlos G. Tensuan, Roman E. Niefes, Roger C. Smith, Rufino B. Joaquin, Nolasco L. Diaz, and Rufino Ibe, who were public officials in Muntinlupa, Metro Manila. They were charged with violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) for enacting Kapasiyahan Bilang 45 on August 1, 1988, which led to the forcible takeover of the New Public Market in Alabang, Muntinlupa, from the Kilusang Bayan sa Paglilingkod ng mga Magtitinda sa Bagong Pamilihang Bayan ng Muntinlupa, Inc. (KBMBPM).
Lease Contract
On September 2, 1985, a 25-year lease contract, renewable for another 25 years, was executed between the Municipality of Muntinlupa and KBMBPM. The cooperative was granted the right to manage and operate the public market for a monthly rental of P35,000. KBMBPM invested P13,479,900 in market improvements.
Enactment of Kapasiyahan Bilang 45
On August 1, 1988, the petitioners enacted Kapasiyahan Bilang 45, which authorized the takeover of the market. On August 19, 1988, the petitioners forcibly took over the market despite the existence of the lease contract and warnings from the Commission on Audit (COA) and Metro Manila Commission (MMC) to take legal steps to rescind the contract.
Motion to Dismiss
On July 24, 1992, the petitioners filed a Motion to Dismiss, citing a Court of Appeals decision that upheld the constitutionality of Resolution No. 45. The Sandiganbayan denied the motion, ruling that the CA decision did not address the constitutionality of the resolution.
Sandiganbayan Decision
On July 26, 1995, the Sandiganbayan found the petitioners guilty of violating Section 3(e) of R.A. No. 3019. They were sentenced to imprisonment and ordered to pay P13,479,900 in actual damages to KBMBPM.
Issue:
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Ruling:
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Ratio:
- Validity of the Lease Contract: The 25-year lease term violated Section 149(3) of B.P. Blg. 337, making the contract void ab initio. Public bidding was also not conducted, further invalidating the contract.
- Good Faith of Petitioners: The petitioners acted in good faith in revoking the lease contract, as it was grossly disadvantageous to the government. They also complied with the directives of COA and MMC.
- No Undue Injury: KBMBPM and its members did not suffer undue injury, as the market vendors were not displaced and continued to operate under the new management.
- Actual Damages: The award of P13,479,900 in actual damages was not justified, as there was no clear evidence of the amount's nature or its receipt by the government.
The Supreme Court emphasized that all elements of the offense must be proven beyond reasonable doubt, and in this case, the prosecution failed to meet this burden.