Case Digest (G.R. No. 156132)
Facts:
In Hilario Jaravata v. Sandiganbayan and the People of the Philippines (G.R. No. L-56170, January 31, 1984), petitioner Hilario Jaravata was then Assistant Principal of Leones Barangay High School in Tubao, La Union. Between April 30 and May 25, 1979, he agreed with six classroom teachers to facilitate the release of their 1978 salary differentials by following up papers in Manila and to be reimbursed for out-of-pocket expenses. Jaravata incurred ₱220.00 in expenses, which he pro-rated at ₱36.00 per teacher. After the teachers received their differentials, four of them—Romeo Dacayanan, Domingo Lopez, Marcela Bautista, Francisco Dulay—paid Jaravata ₱118.00, ₱100.00, ₱50.00, and ₱70.00 respectively. The Sandiganbayan, in Criminal Case No. 873, found that these payments exceeded the agreed ₱36.00 share, totaling an excess of ₱194.00, and convicted Jaravata of violating Section 3(b) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), sentencing him to one–four years’ inCase Digest (G.R. No. 156132)
Facts:
- Parties and roles
- Petitioner: Hilario Jaravata, Assistant Principal of Leones, Tubao, La Union Barangay High School.
- Respondents: The Sandiganbayan and the People of the Philippines.
- Procedural background
- Charge: Violation of Section 3(b) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) for “requesting or receiving” sums from classroom teachers—P118.00, P100.00, P50.00, and P70.00 (total P338.00)—in connection with facilitating the release of their 1978 salary differentials (April 30–May 25, 1979).
- Trial court decision (Sandiganbayan, Criminal Case No. 873): Convicted beyond reasonable doubt; sentenced to indeterminate imprisonment of one (1) to four (4) years, perpetual special disqualification from public office, and costs; no civil liability pronounced because the money was refunded.
- Supreme Court petition: Raises factual and legal issues; opts to resolve the legal issue concerning the scope of “official intervention” under Section 3(b).
Issues:
- Statutory construction
- Does Section 3(b) of R.A. 3019 penalize a public officer who receives gifts or benefits when his “intervention” in the transaction is not mandated by law?
- What is the meaning of the phrase “in his official capacity has to intervene under the law” in Section 3(b)?
- Factual applicability
- Did Jaravata’s role in expediting the payment of salary differentials amount to “official intervention” required by law?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)