Case Digest (G.R. No. 238304) Core Legal Reasoning Model
Facts:
The case involves Charita M. Chan (Petitioner), who was charged by the People of the Philippines (Respondent) with violations related to the Anti-Graft and Corrupt Practices Act under Republic Act No. 3019. The relevant proceedings began with the filing of two Informations against Chan on August 10, 2016, in connection with her role as the Mayor of Babatngon, Leyte. The charges were both centered on violations of Section 3(j) of the Act, with Criminal Case No. SB-16-CRM-0511 focusing on her approval of a Mayor's Permit for the operation of a cockpit in favor of Nicomedes Alde, a local government official prohibited from holding such an interest. Conversely, Criminal Case No. SB-16-CRM-0512 pertained to her granting a permit to the Liga ng mga Barangay, which was also disseminated by prohibited members. A warrant for her arrest was issued on September 7, 2016, and Chan subsequently pleaded not guilty during her arraignment on May 25, 2017. The prosecution relied on testimoni
Case Digest (G.R. No. 238304) Expanded Legal Reasoning Model
Facts:
- On August 10, 2016, two Informations were filed against petitioner Charita M. Chan, then-Municipal Mayor of Babatngon, Leyte, for violation of Section 3(j) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act).
- Criminal Case No. SB-16-CRM-0511 charged Chan with approving a Mayor’s Permit favoring Nicomedes Alde for operating the Babatngon Gallera (a cockpit), despite Alde’s ineligibility owing to his status as a government official engaged in prohibited activities.
- Criminal Case No. SB-16-CRM-0512 charged her with issuing a Mayor’s Permit in favor of the Liga ng mga Barangay for holding cockfights every Saturday, even though such activity was barred by law (notably by provisions of Presidential Decree No. 449 and a Municipal Ordinance).
- A warrant of arrest was issued on September 7, 2016, and during arraignment on May 25, 2017, Chan pleaded not guilty.
- The prosecution presented key testimonies from municipal officials (Balboa, Pulma, and Rondina) and documentary evidence, including Exhibit “H” (the Mayor’s Permit), which was pivotal in establishing that Chan had knowingly issued the permit in favor of an ineligible body.
- The defense did not present any contrary evidence but submitted memoranda arguing insufficiency of evidence and the absence of criminal intent.
- The Sandiganbayan, in its February 20, 2018 Decision, acquitted Chan in Criminal Case No. SB-16-CRM-0511 for lack of evidence but found her guilty beyond reasonable doubt in Criminal Case No. SB-16-CRM-0512 for having knowingly granted a permit to the Liga ng mga Barangay, whose members were legally barred from holding interest in a cockpit operation.
Issues:
- Whether the trial court erred in convicting Chan in Criminal Case No. SB-16-CRM-0512 despite alleged insufficiency of evidence on one hand and failure to establish that she was the actual perpetrator on the other.
- Whether the court improperly determined that Chan had the requisite criminal intent, considering that criminal intent is a disputed element in malum prohibitum offenses such as violations under Section 3(j) of RA 3019.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)