Title
Fuentes vs. People
Case
G.R. No. 186421
Decision Date
Apr 17, 2017
A mayor refused to renew a business permit based on unverified rumors, causing undue harm to the proprietor. Convicted of graft, he faced imprisonment, disqualification, and damages.

Case Digest (G.R. No. 154402)
Expanded Legal Reasoning Model

Facts:

  • Parties and Procedural Posture
    • Petitioner Roberto P. Fuentes, Municipal Mayor of Isabel, Leyte, was charged under Article 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
    • Private complainant Fe N. Valenzuela, sole proprietor of Triple A Ship Chandling and General Maritime Services, alleged undue injury from refusal to renew her business permit.
  • Refusal to Renew Permit and Business Interruption
    • In early 2002, Valenzuela paid fees and secured LGU approvals (all municipal officials’ signatures and a police clearance), yet Fuentes refused to sign Triple A’s permit.
    • Fuentes issued an unnumbered memorandum to port and BOC officials alleging Valenzuela’s involvement in smuggling and drug trading, prompting a Cease and Desist Order.
    • Triple A operated briefly on temporary permits but was shut down; its goods for M/V Ace Dragon spoiled, and operations were suspended from 2002 until permit issuance in 2007.
  • Trial Court Proceedings
    • Fuentes pleaded not guilty on September 15, 2006.
    • The Sandiganbayan convicted him on September 30, 2008, sentencing him to 6 years 1 month–10 years 6 months imprisonment, perpetual disqualification from public office, and P200,000 nominal damages.
    • A motion for reconsideration was denied on February 16, 2009, leading to this petition for certiorari.

Issues:

  • Primary Issue
    • Whether the Sandiganbayan correctly convicted Fuentes of violating Section 3(e) of RA 3019 by acting with manifest partiality or bad faith and causing undue injury.
    • Whether the elements of a corrupt practice under Section 3(e) were sufficiently proven.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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