Case Digest (G.R. No. 1786) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 126995, decided on October 6, 1998, Imelda R. Marcos (Petitioner) challenged her conviction by the Sandiganbayan (First Division) for violation of Section 3(g) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act). Docketed as Criminal Case No. 17450, the Information charged that on or about June 8, 1984, in Makati, as then Chairman of the Philippine General Hospital Foundation, Inc. (PGHFI) and ex officio Chairman of the Light Rail Transit Authority (LRTA), Marcos conspired with Jose P. Dans, Jr. (then Vice-Chairman of LRTA) to execute a Lease Agreement (Exhibit “B”) between LRTA and PGHFI under terms “manifestly and grossly disadvantageous to the government.” Subsequently, PGHFI, represented by Marcos, sub-leased the same property to Transnational Construction Corporation (TNCC) at a monthly rental seven times higher (Exhibit “D”). After a deadlock in the three-member First Division, a five-member Special Division was constituted and then dissolved by Case Digest (G.R. No. 1786) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Indictment
- Imelda R. Marcos (petitioner) and Jose P. Dans, Jr. (co-accused) served as ex officio Chair and Vice-Chair, respectively, of the Light Rail Transit Authority (LRTA).
- Indicted under Section 3(g) of RA 3019 (Anti-Graft and Corrupt Practices Act) for conspiring to enter a manifestly and grossly disadvantageous Lease Agreement on or about June 8, 1984.
- Lease and Sublease Agreements
- Lease Agreement (Exh. “B”): LRTA leased 7,340 sqm in Pasay City to the Philippine General Hospital Foundation, Inc. (PGHFI) for ₱102,760/month over 25 years; signed by Dans for LRTA and Marcos for PGHFI.
- Sublease Agreement (Exh. “D”): PGHFI subleased the same lot to Transnational Construction Corporation (TNCC) for ₱734,000/month over 25 years; signed by Marcos for PGHFI and TNCC’s president.
- Procedural History in Sandiganbayan
- First Division (Justices Garchitorena, Balajadia, Atienza) failed to reach a unanimous vote.
- Presiding Justice Garchitorena formed a five-member Special Division (Adm. Order No. 288-93); dissolved it (Adm. Order No. 293-93) after an informal lunch meeting of three justices.
- On September 24, 1993, the reconstituted First Division convicted both Marcos and Dans.
- Supreme Court Review
- On January 29, 1998, the Third Division affirmed Marcos’s conviction (G.R. No. 126995) but reversed Dans’s (G.R. No. 127073), relying mainly on the rental disparity.
- Marcos filed a Motion for Reconsideration (MFR), raising (a) lack of proof she acted as a public officer; (b) insufficient evidence of gross disadvantage; (c) due process violations; and (d) right to speedy disposition.
- The Court en banc heard oral arguments on September 10, 1998, and invited memoranda.
Issues:
- Public-Officer Element
- Gross-Disadvantage Element
- Procedural Due Process
- Speedy-Disposition Right
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)