Title
Garcia vs. Sandiganbayan
Case
G.R. No. 155574
Decision Date
Nov 20, 2006
A regional director of the Land Transportation Office was acquitted of 56 counts of violation of the Anti-Graft and Corrupt Practices Act due to lack of sufficient evidence for unauthorized vehicle borrowing.
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Case Digest (G.R. No. 155574)

Facts:

  • Timoteo A. Garcia, the petitioner, was convicted by the Sandiganbayan of 56 counts of violating Section 3(b) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
  • A complaint was filed by Maria Lourdes Miranda against Garcia, who was the Regional Director of the Land Transportation Office (LTO) in Region X, along with Gilbert G. Nabo and Nery Tagupa, employees of the same office.
  • The complaint alleged that the accused frequently borrowed vehicles from Oro Asian Automotive Center Corporation, a company that regularly transacted with the LTO.
  • On August 14, 1997, 57 Informations were filed against the accused for borrowing vehicles from January 1993 to November 1994.
  • The charges claimed that the accused abused their official positions for personal use of the vehicles, causing undue injury to the complainant and the company.
  • Arrest orders were issued on August 22, 1997, and Garcia posted a surety bond for provisional liberty on October 6, 1997.
  • During the trial, witnesses testified about the vehicle borrowings and delivery receipts.
  • Garcia denied the allegations, arguing that the prosecution did not prove the essential elements of the crime.
  • On May 6, 2002, the Sandiganbayan convicted Garcia, sentencing him to imprisonment, while Tagupa was acquitted due to lack of evidence.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted the petition, reversing and setting aside the Sandiganbayan's decision.
  • Timoteo A. Garcia was acq...(Unlock)

Ratio:

  • The Supreme Court found that the prosecution did not establish one essential element of the crime under Section 3(b) of Republic Act No. 3019, specifically the requirement that the vehicle borrowings must relate to a government contract or transaction in which the public officer had the right to intervene.
  • The prosecution failed to specify any transactions between the company and the LTO that Garcia was involved in ...continue reading

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