Title
Cadiao-Palacios vs. People
Case
G.R. No. 168544
Decision Date
Mar 31, 2009
A mayor and official demanded and received payments from a contractor under threat of withholding project funds, violating anti-graft laws; conviction upheld.
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Case Digest (G.R. No. 168544)

Facts:

Background of the Case:

  • Petitioner Linda Cadiao-Palacios was the mayor of the Municipality of Culasi, Antique, from July 1998 to June 2001.
  • During her administration, several infrastructure projects initiated by her predecessor, Mayor Aida Alpas, remained partially unpaid. These included the Janlagasi Diversion Dam, San Luis Diversion Dam, Caridad-Bagacay Road, and San Juan-Tumao Road, contracted by L.S. Gamotin Construction (L.S. Gamotin) with a total project cost of P2 million. The municipality owed the contractor P791,047.00.

The Allegations:

  • Petitioner and Victor S. Venturanza, the Municipal Security Officer, were charged with violating Section 3(b) of Republic Act (R.A.) No. 3019 (Anti-Graft and Corrupt Practices Act).
  • The Information alleged that in January 1999, petitioner and Venturanza demanded money from Grace Superficial of L.S. Gamotin Construction, threatening that the final payment for the projects would not be released unless the demand was met. They allegedly received P15,000.00 in cash and P162,400.00 through a Land Bank of the Philippines (LBP) check.

Trial Proceedings:

  • Both accused pleaded "Not Guilty" and posted bail.
  • The prosecution presented Grace Superficial as its sole witness. She testified that petitioner demanded money under threat of withholding final payments. She gave P15,000.00 to petitioner's husband and later issued a check for P162,400.00 payable to Venturanza, which he encashed.
  • The defense presented several witnesses, including petitioner and Venturanza, who denied the allegations. Venturanza claimed the P162,400.00 was a loan for his trip to Australia, which he later repaid.

Sandiganbayan Decision:

  • The Sandiganbayan found both accused guilty beyond reasonable doubt of violating Section 3(b) of R.A. No. 3019. They were sentenced to imprisonment and ordered to pay costs.

Issue:

  1. Whether petitioner and Venturanza violated Section 3(b) of R.A. No. 3019 by demanding and receiving "grease money" in connection with government contracts.
  2. Whether the Sandiganbayan erred in giving credence to the testimony of Grace Superficial and in finding that the elements of the crime were proven beyond reasonable doubt.
  3. Whether the defense's claim that the case was politically motivated had merit.

Ruling:

The Supreme Court denied the petition and affirmed the Sandiganbayan's decision. The Court found that the prosecution sufficiently established the elements of the crime under Section 3(b) of R.A. No. 3019. The testimony of Grace Superficial, corroborated by documentary evidence, proved that petitioner demanded and received "grease money" through Venturanza. The Court upheld the Sandiganbayan's factual findings and credibility assessment, ruling that no cogent reason existed to overturn the conviction.

Ratio:

  1. Elements of the Crime:

    • Section 3(b) of R.A. No. 3019 penalizes public officers who directly or indirectly request or receive any gift, share, percentage, or benefit in connection with government contracts or transactions.
    • The elements of the crime are:
      • The offender is a public officer.
      • The offender requests or receives a gift, share, percentage, or benefit.
      • The request or receipt is in connection with a government contract or transaction.
      • The public officer has the right to intervene in the transaction in an official capacity.
  2. Credibility of Witnesses:

    • The Sandiganbayan's assessment of witness credibility is accorded great respect, as it had the opportunity to observe the witnesses firsthand.
    • Grace Superficial's testimony was credible and consistent, and no ill motive was proven to discredit her.
  3. Conspiracy:

    • The circumstances, including Venturanza's receipt of the check and his use of a municipal vehicle to encash it, established that petitioner and Venturanza conspired to commit the crime.
  4. Defense Claims:

    • The defense's claim that the case was politically motivated was unsupported by evidence.
    • Venturanza's claim that the money was a loan was implausible, as the timing and circumstances suggested it was "grease money."
  5. Proof Beyond Reasonable Doubt:

    • The prosecution met the burden of proof, as the evidence produced moral certainty of the accused's guilt.

Conclusion:

The Supreme Court upheld the conviction of petitioner and Venturanza, finding that the Sandiganbayan correctly applied the law and that the evidence supported the verdict. The petition was denied for lack of merit.


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