Title
Fuentes vs. People
Case
G.R. No. 186421
Decision Date
Apr 17, 2017
Former Municipal Mayor Roberto P. Fuentes is convicted of violating the Anti-Graft and Corrupt Practices Act for refusing to renew a business permit without legal basis, causing undue injury to the business operator and resulting in imprisonment, disqualification from public office, and payment of damages.
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Case Digest (G.R. No. 186421)

Facts:

  • The case involves Roberto P. Fuentes, the Municipal Mayor of Isabel, Leyte, and the People of the Philippines.
  • Fuentes was charged with violating Section 3 (e) of Republic Act No. 3019, the "Anti-Graft and Corrupt Practices Act."
  • The charge arose from Fuentes's refusal to renew the business permit of Fe Nepomuceno Valenzuela, owner of Triple A Ship Chandling and General Maritime Services (Triple A).
  • Triple A had been operating in the Port of Isabel since 1993.
  • Despite Valenzuela's compliance with all requirements and approval from other municipal officers, Fuentes refused to sign the permit in 2002.
  • Fuentes cited rumors of Valenzuela's involvement in smuggling and drug trading as the reason for his refusal.
  • This refusal led to the suspension of Triple A's operations and spoilage of goods.
  • The Sandiganbayan found Fuentes guilty beyond reasonable doubt, sentencing him to imprisonment, perpetual disqualification from public office, and ordering him to pay damages to Valenzuela.
  • Fuentes's motion for reconsideration was denied, leading to this petition for review on certiorari.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition and affirmed the Sandiganbayan's decision.
  • Fuentes was found guilty beyond reasonable doubt of violating Section 3 (e) of RA 3019.
  • He was sentenced to imprisonment for an indeterminate period of six (6) years and one (1) month to ten (10) years and six (6) months.
  • Fuentes was also perpetually disqualified from public office.
  • Additionally, ...(Unlock)

Ratio:

  • Public Officer: Fuentes was a public officer, being the Municipal Mayor of Isabel, Leyte, at the time of the acts complained of.
  • Manifest Partiality and Bad Faith: Fuentes's refusal to issue the business permit was done with manifest partiality and evident bad faith. Despite rumors implicating all ship chandlers in illegal activities, Fuentes singled out Valenzuela's Triple A. He issued permits to other chandlers and even to Valenzuela's other business, Gemini Security, indicating selective enforcement. Fuentes's actions were not based on any legal or factual basis, as Valenzuela had secured clearances from various law enforcement agencies.
  • Undue Injury: Fuentes's refusal to issue the business permit and his issuance of a memorandum barring Triple A from operations caused undue injury to Valenzuela. The suspension of Triple A's operations resulted in pecuniary loss, although the exact amount was not proven with certainty. The Court awarded temperate damages instead of nominal damages, considering the substantial but unquantified loss.
  • Legal Basis: ...continue reading

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