G.R. No. 94955 - Coronado vs. Sandiganbayan

Juan Coronado was a newly hired process server in the Office of the Clerk of Court of the Regional Trial Court (RTC) of Antipolo, Rizal.
His duty involved serving court orders and other judicial documents, a task critical to the proper administration of justice.

On 11 July 1984, the Regional Trial Court of Rizal issued an Order denying the plaintiffs’ motion for reconsideration in Civil Case No. 290-A ("Pinagkamaligan Indo-Agro-Development Corporation, et al. v. Mariano Lim et al.").
On 31 August 1984, defendant Mariano Lim, one of the parties in the civil case, realized that the aforementioned Order had not been served on the plaintiffs, causing him concern over the effect on the finality of the decision.
Representations were made by Lim to Executive Judge Antonio V. Benedicto, requesting that the Order be served on plaintiffs’ counsel, Atty. Patrocinio Palanog.
The petitioner, as the designated process server, was directed to serve the Order. His initial attempt failed due to the inability to locate Atty. Palanog’s address.
A subsequent attempt on 02 September 1984, despite locating the address, was unsuccessful when Atty. Palanog’s family was absent, and only a non-family member was present.
The Order remained unserved until further developments were noted:

On 22 February 1985, Lim revisited the courthouse and was informed that the case had been archived with others (29 cases in total).
On 25 February 1985, Lim discovered additional records evidencing that there had been a return, dated 4 September 1984, indicating that contact with Atty. Palanog was unsuccessful; an entry in the Order itself; and a subsequent return, dated 25 February 1985, asserting that the Order was served on the plaintiffs.

The substantial delay—approximately a 5-month lapse—in serving the Order formed the basis of the controversy.

Juan Coronado was charged and subsequently convicted by the Sandiganbayan for violating Section 3(f) of Republic Act No. 3019, known as the Anti-Graft and Corrupt Practices Act.
The specific allegation was that by neglecting or refusing, without sufficient justification and after due demand, to serve the court Order in a timely manner, he acted in a manner that could potentially secure an undue advantage for one party over another in the pending civil case.
The charge implied that his neglect was intended either to obtain, directly or indirectly, a pecuniary or material benefit for an interested party or to discriminate against another party.

Whether the petitioner’s failure to successfully serve the Order constitutes sufficient grounds for conviction under Section 3(f) of RA 3019.

Did his neglect or refusal—despite being unarguably established—meet the statutory element of acting “for the purpose of obtaining, directly or indirectly, from any person interested in the matter some pecuniary or material benefit or advantage in favor of, or discriminating against, another interested party”?

Whether the absence of evidence demonstrating any corrupt or discriminatory intent on the part of the petitioner negates the fulfillment of the fourth element of the offense.

Can a mere delay or failure in service, regardless of its prejudicial effects on the judicial process, be equated with the deliberate intention of obtaining advantage or discriminating?

The application of the presumption of innocence and the requirement that guilt must be proven beyond a reasonable doubt, particularly in light of the severe penalty imposed by the Anti-Graft and Corrupt Practices Act.