Title
Cuerpo vs. People
Case
G.R. No. 203382
Decision Date
Sep 18, 2019
Public officials convicted for violating Anti-Graft Act after unlawfully demolishing settlers' homes without due process, causing undue injury.

Case Digest (G.R. No. 203382)
Expanded Legal Reasoning Model

Facts:

Context of the Case: This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the Sandiganbayan's January 31, 2012 Decision and September 7, 2012 Resolution. The petitioners, Mayor Pedro S. Cuerpo, Engr. Fernando RoAo, and Barangay Captain Salvador Simbulan, were found guilty of violating Section 3(e) of Republic Act (R.A.) No. 3019, the Anti-Graft and Corrupt Practices Act.

Complainants and Accusations:
The private complainants, including Leticia B. Nanay, Nancy B. Barsubia, Gemma I. Bernal, Maria Victoria G. Ramirez, Crisanta S. Oxina, and Adelaida H. Ebio, were informal settlers who relocated to a piece of land in Barangay Burgos, Rodriguez, Rizal, after being evicted from their previous location in Quezon City. They had legally purchased the land and obtained Transfer Certificate of Title (TCT) No. 436865.

Events Leading to the Complaint:
The petitioners, acting in their official capacities, refused to allow the private complainants to relocate to Barangay Burgos without a development permit. The private complainants were denied building permits despite submitting applications. On September 22, 2003, their makeshift shelters were summarily demolished by a team led by Barangay Captain Simbulan and Capt. Renato Evasco, acting on the orders of Mayor Cuerpo. The demolition was conducted without prior notice, court order, or compliance with legal procedures for eviction and demolition.

Key Points from the Facts:

  • The private complainants were lawful owners of the land where their shelters were constructed.
  • The petitioners required a development permit, which was unreasonable given the circumstances.
  • The demolition was carried out in violation of due process and without legal justification.

Issues:

The primary issue before the Court was whether the Sandiganbayan correctly convicted the petitioners for violation of Section 3(e) of R.A. No. 3019. The petitioners argued that they acted in good faith and in compliance with the law, and that the prosecution failed to prove the elements of manifest partiality, evident bad faith, or gross inexcusable negligence and undue injury.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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