Facts:

The case involves Timoteo A. Garcia, the petitioner, who was convicted by the Sandiganbayan of 56 counts of violating Section 3(b) of Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act. The events leading to the conviction began with a complaint 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 motor vehicles from Oro Asian Automotive Center Corporation, a company that regularly transacted with the LTO for vehicle registration and related services.

On August 14, 1997, 57 Informations were filed against the accused, detailing various instances of borrowing vehicles from the company between January 1993 and November 1994. The specific charges indicated that the accused took advantage of their official positions to borrow vehicles for perso...

Facts:

Background: The case originated from a complaint filed by Maria Lourdes Miranda against Timoteo A. Garcia, Gilbert G. Nabo, and Nery Tagupa, employees of the Land Transportation Office (LTO) Region X, for violating Section 3(b) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act. The complaint alleged that the accused frequently borrowed motor vehicles from Oro Asian Automotive Center Corporation (the Company), which regularly transacted with the LTO.

Charges: On August 14, 1997, 57 Informations were filed with the Sandiganbayan against Garcia, Nabo, and Tagupa. Each Information detailed specific dates and descriptions of the vehicles allegedly borrowed by the accused, with the first case (Crim. Case No. 24042) serving as the template for the rest. The accused were charged with conspiring to borrow vehicles for personal use, knowing that the Company regularly transacted with their office.

Prosecution’s Evidence: The prosecution presented two key witnesses: Estanislao Barrete Yungao, a driver and liaison officer for the Company, and Aurora J. Chiong, the Vice-President and General Manager of the Company. Yungao testified that Garcia regularly requested to borrow vehicles for personal use, particularly to visit his farm. He also stated that delivery receipts were issued for each borrowed vehicle. Chiong corroborated Yungao’s testimony, adding that Garcia would often call her directly to request the vehicles.

Defense’s Evidence: Garcia denied borrowing any vehicles, arguing that his signature did not appear on any delivery receipts. He admitted that the Company regularly transacted with the LTO but maintained that he had no ill feelings with the Company’s owners. He also claimed that his subordinates borrowed vehicles from friends, a practice he discouraged but could not entirely stop.

Sandiganbayan Decision: On May 6, 2002, the Sandiganbayan convicted Garcia of 56 counts of violating Section 3(b) of RA 3019. Tagupa was acquitted due to lack of evidence, and the cases against Nabo, who remained at large, were archived.

Issue:

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Ruling:

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Ratio:

1. Elements of Section 3(b) of RA 3019: For a conviction under Section 3(b), the prosecution must prove: (1) the offender is a public officer; (2) they requested or received a gift, benefit, or advantage; (3) the request/reception was on their behalf or another’s; (4) it was in connection with a government contract or transaction; and (5) the public officer had the right to intervene in the transaction. The Court found that the prosecution failed to establish the fourth element, as it did not specify the transactions Garcia allegedly intervened in when borrowing the vehicles.

2. Insufficient Evidence: The delivery receipts and witness testimonies did not conclusively prove that Garcia received the vehicles. His signature was absent from the receipts, and the identities of those who allegedly picked up the vehicles were uncertain.

3. No Basis for Other Crimes: The prosecution did not provide evidence that Garcia committed Direct Bribery (e.g., accepting gifts in exchange for official acts) or Indirect Bribery (e.g., accepting gifts by reason of his office).

4. Speculation and Conjecture: The Sandiganbayan’s decision was based on assumptions unsupported by evidence, violating Garcia’s right to be presumed innocent until proven guilty.

The Court emphasized that in criminal cases, every element of the crime must be proven beyond reasonable doubt. The prosecution’s failure to meet this standard warranted Garcia’s acquittal.