Facts:

• Florencia L. Garcia-Diaz and Jose G. Solis filed petitions for review against the Sandiganbayan's decision.
• They were found guilty of violating Section 3(g) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act.
• Solis was also found guilty of falsifying public documents under Article 171, paragraph 4 of the Revised Penal Code.
• The case stemmed from a Compromise Agreement involving 4,689 hectares within the Fort Magsaysay Military Reservation, public domain land nearly registered under Garcia-Diaz's name.
• In 1976, Flora L. Garcia, Garcia-Diaz's predecessor, applied to register a 16,589.84-hectare property in Nueva Ecija, claiming lineage from the Spanish regime.
• Although the Republic opposed the application, the Court of First Instance of Nueva Ecija approved it, but the Court of Appeals later reversed this decision.
• During the appeal, Garcia-Diaz's counsel negotiated a Compromise Agreement with the Republic, which the Court of Appeals approved.
• An investigation revealed false representations in the agreement, leading to criminal charges against Garcia-Diaz, Solis, and other public officers.

Issue:

• (Unlock)

Ruling:

1. Yes, a private person can be charged and convicted under the Anti-Graft and Corrupt Practices Act if they conspire with a public officer.
2. Yes, conspiracy can exist even if the public officer is not a party to the contract or transaction, provided there is a common scheme or purpose.
3. Yes, petitioner Jose G. Soli...(Unlock)

Ratio:

• The court held that a private person could be convicted under the Anti-Graft and Corrupt Practices Act if they conspire with a public officer.
• The statute's policy aims to repress acts of graft and corruption by both public officers and private persons.
• Garcia-Diaz conspired with Solicitor General Galvez and Solis to execute a Compromise Agreement grossly disadvantageous to the government.
• Solis' February 12, 1998 Letter falsely stated that part of the proper...continue reading