Case Digest (G.R. No. 154402) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On January 8, 2002, in the Municipality of Isabel, Leyte, Roberto P. Fuentes, then Municipal Mayor, unlawfully withheld the renewal of the business permit of Fe Nepomuceno Valenzuela, sole proprietor of Triple A Ship Chandling and General Maritime Services, despite her having paid fees and secured clearances from all other municipal officials and the Philippine National Police. Fuentes issued an unnumbered memorandum to port authorities and the Bureau of Customs alleging her involvement in smuggling and drug trading, prompting a Cease and Desist Order that shut down her operations. From 2002 until 2006, Valenzuela’s ship chandling business was paralyzed, causing spoilage of perishable goods and financial losses, until a permit was finally granted in 2007. Valenzuela filed a complaint for violation of Section 3(e) of Republic Act No. 3019 in Sandiganbayan Criminal Case No. 28342. On September 30, 2008, the Sandiganbayan found Fuentes guilty beyond reasonable doubt and sentenced h Case Digest (G.R. No. 154402) Expanded Legal Reasoning Model
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)