Case Digest (G.R. No. 94955)
Facts:
- Juan Coronado, the petitioner, was convicted by the Sandiganbayan for violating Section 3(f) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act.
- Coronado, a newly hired Process Server in the Office of the Clerk of Court of the RTC of Antipolo, Rizal, was charged alongside Cesar Villamor and Oscar Caing in an Information dated November 26, 1985, under Criminal Case No. 11035.
- The arraignment was postponed multiple times due to a pending reinvestigation by the Tanodbayan.
- An "Omnibus Motion to Admit Amended Information and To Dismiss the Case Against Accused Cesar Villamor and Oscar Caing" was filed by the Tanodbayan on February 9, 1987.
- On September 23, 1987, the Sandiganbayan allowed the Amended Information against Coronado to proceed.
- The charge against Coronado stated that he willfully neglected to serve a copy of an Order dated July 11, 1984, which denied the plaintiffs' Motion for Reconsideration.
- Coronado's delay in serving the Order was alleged to have given undue advantage to the plaintiffs and discriminated against the defendants.
- The Sandiganbayan found that Coronado failed to serve the Order for over five months, resulting in his conviction and an indeterminate sentence of six years and one month to nine years and one day.
- Coronado subsequently filed a petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court reversed the Sandiganbayan's judgment and acquitted Juan Corona...(Unlock)
Ratio:
- The Supreme Court analyzed the elements necessary for a conviction under Section 3(f) of the Anti-Graft and Corrupt Practices Act, which include:
- The offender must be a public officer.
- There must be neglect or refusal to act without sufficient justification after due demand.
- A reasonable time must elapse without action.
- The failure to act must be intended to benefit an interested party or discriminate against another.
- While Coronado neglected his duty as a public officer, the prosecution did not prove the fourth element—his neglect was not shown to b...continue reading
Case Digest (G.R. No. 94955)
Facts:
The case involves Juan Coronado, the petitioner, who was convicted by the Sandiganbayan for violating Section 3(f) of Republic Act No. 3019, known as the Anti-Graft and Corrupt Practices Act. The events leading to this conviction began when Coronado, a newly hired Process Server in the Office of the Clerk of Court of the Regional Trial Court (RTC) of Antipolo, Rizal, was charged alongside Cesar Villamor and Oscar Caing in an Information dated November 26, 1985, under Criminal Case No. 11035. The arraignment was postponed multiple times due to a pending reinvestigation by the Tanodbayan. Following the reinvestigation, an "Omnibus Motion to Admit Amended Information and To Dismiss the Case Against Accused Cesar Villamor and Oscar Caing" was filed by the Tanodbayan on February 9, 1987. On September 23, 1987, the Sandiganbayan granted this motion, allowing the Amended Information against Coronado to proceed. The charge against him stated that from August 31, 1984, to February 21, 1985, he willfully neglected to serve a copy of an Order dated July 11, 1984, issued by Executive Judge Antonio V. Benedicto in Civil Case No. 290-A. This Order denied the plaintiffs' Motion for Reconsideration, and Coronado's delay in serving it was alleged to have given undue adva...