G.R. No. 197142 - Cruz vs. People

A complaint for ejectment was filed on October 22, 1986, before the Municipal Trial Court (MTC) of Bulacan by plaintiffs Maria Rosario Batongbacal, Celso S. Lazaro, Lauro S. Lazaro, Consorcia L. Santiago, Rodolfo L. Lazaro, and Pablo R. Santiago.
The defendants were spouses Marcelo L. Del Rosario and Amelia V. Del Rosario, and the case was docketed as Civil Case No. 1526.
The case was raffled to Judge Manuel R. Ortiguerra and decided in favor of the plaintiffs on November 17, 1989.
The judgment attained finality on December 27, 1989 and became fully enforceable on December 27, 1990.
Subsequent motions for the issuance of a writ of execution and a writ of demolition were filed, with multiple alias writs being necessary due to resistance in the enforcement process.

On March 5, 1993, petitioners Gil “Boying” R. Cruz, former Mayor Serafin N. Dela Cruz, and Dennis C. Carpio (together with Isidoro S. Mauricio and Jose A. Aspuria) allegedly obstructed the enforcement of the fourth alias writ of execution and the third alias writ of demolition.
The interference was connected to a dispute arising from Civil Case No. 1526, where parts of a property allegedly owned by the Batongbacals (or held as part of their claim) were subject to eviction and demolition.
Attorney Mario A. Batongbacal, acting as complainant and attorney-in-fact for his wife, lodged a complaint with the Office of the Ombudsman regarding the incident.

Pre-trial proceedings were held on December 12 and 13, 1996, during which the roles and identities of the accused were clarified:

Serafin M. Dela Cruz was identified as the Municipal Mayor of Bocaue, Bulacan on the material date.
Gil “Boying” Cruz served as the Acting Municipal Administrator.
Dennis Carpio was the Secretary of the Sangguniang Bayan and Private Secretary to the Mayor.

Stipulations were made regarding the pending nature of another related civil action (Civil Case No. 774-M-94) and the administrative status of other facts, such as the issuance and return of several alias writs of execution and demolition.
Testimonies from a range of witnesses, including letters, police reports, and an order from Judge Ortiguerra, were introduced to document the multiple attempts to enforce the writs.

The prosecution presented several witnesses—including Atty. Mario A. Batongbacal (the private complainant), Sheriff Bienvenido G. Villarente, Process Server Dioscoro B. Aligato, and former Deputy Sheriff Gregorio M. Pagulayan—to establish that:

The petitioners, while executing or attempting to facilitate the enforcement of the writs, acted in a manner that obstructed and delayed the execution process.
Their actions caused “undue injury” to the complainant and inadvertently benefited a private party, Alexander Halili, by permitting the continued occupation of a structure that the court had ordered demolished.

Detailed witness accounts described the sequence of events—ranging from the initial issuance of partial execution motions to the multiple alias writs and eventual intervention at the demolition site—underscoring the alleged obstruction.

The defense presented its version of events through testimonies by the petitioners themselves (Cruz, Mayor Dela Cruz, and Carpio) and their co-accused (Aspuria and Alexander Halili), asserting that:

Their actions were in the normal course of performing their official duties and did not involve any willful or conspiratorial obstruction of court orders.
There was genuine confusion regarding the property subject to demolition, and the demolition efforts were halted following a court order issued by Judge Ortiguerra.

Petitioner Cruz’s account of being summoned by the Mayor and later accompanying him to the demolition site and judge’s sala.
Mayor Dela Cruz’s version that emphasized the duty to protect constituents and his attempt to clarify the proper location and properties subject to demolition.
Petitioner Carpio’s description of simply performing his duties as Private Secretary during the incident.
The testimony of Aspuria, which stressed that he was not present at the demolition site and his subsequent claim of being erroneously included based on his business relations.
Alexander Halili’s detailed narrative of his property claims, the intervening demolition, and his efforts to seek clarification from the Mayor.

The Sandiganbayan, in its Decision dated September 10, 2008 and Resolution dated May 30, 2011 (CRIM. CASE NO. 23147), found petitioners Serafin M. Dela Cruz, Gil “Boying” R. Cruz, and Dennis C. Carpio guilty beyond reasonable doubt of violating Section 3(e) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act).
The decision imposed an indeterminate penalty of imprisonment ranging from six (6) years and one (1) month to ten (10) years.
Due to the death of accused Isidoro S. Mauricio, the case against him was dismissed, and petitioner Jose “Jerry” S. Aspuria was acquitted for insufficiency of evidence.

Whether the Sandiganbayan erred in its finding of a conspiracy among the petitioners by attributing to them a deliberate and coordinated effort to obstruct the enforcement of the court’s writs.

Whether the mere presence of petitioners at the demolition site, as well as their assistance in routine official functions, can be equated to active participation in a criminal conspiracy.

Whether the Sandiganbayan erred in declaring petitioners guilty beyond reasonable doubt of violating Section 3(e) of RA 3019.

Whether there was sufficient evidence to prove that petitioners acted with manifest partiality, evident bad faith, or gross inexcusable negligence such that their actions granted a private party unwarranted benefits or advantages.

The effect of the death of petitioner Mayor Dela Cruz on the criminal and civil liabilities arising from the case.