Case Digest (G.R. No. 6516) Core Legal Reasoning Model
Facts:
In the case of Arturo A. Mejorada v. The Honorable Sandiganbayan and the People of the Philippines (G.R. Nos. 51065-72, June 30, 1987), the petitioner, Arturo A. Mejorada, was a government public officer employed as a right-of-way agent in the Office of the Highway District Engineer in Pasig, Metro Manila from February 1974 until December 31, 1978. His primary duty was to negotiate with property owners affected by highway construction projects to compensate them for damages.
From October 1977 to February 1978, Mejorada was charged with violating Section 3(e) of Republic Act No. 3019 (the Anti-Graft and Corrupt Practices Act). The Provincial Fiscal filed eight informations against him which were jointly tried before the Sandiganbayan. Each information detailed that Mejorada, by conspiring with unidentified accomplices, fraudulently facilitated approval of government compensation claims for landowners whose properties were affected by the widening of the Pasig-Sta. Cruz-Calamba
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Case Digest (G.R. No. 6516) Expanded Legal Reasoning Model
Facts:
- Employment and Position of Petitioner
- Arturo A. Mejorada was employed first as a temporary skilled laborer in the Bureau of Public Works starting March 16, 1947.
- From February 1974 to December 31, 1978, he served as Right-of-Way Agent in the Office of the Highway District Engineer, Pasig, Metro Manila.
- His primary duty was to negotiate with property owners affected by highway constructions for compensation purposes.
- Circumstances of the Offenses
- The affected properties were along the Pasig-Sta. Cruz-Calamba Road, 2nd IBRD Project, at Binangonan, Rizal.
- Claimants included Isagani de Leon, Isaac Carlos, Napoleon Maybituin, Dominga Villaroza, Florentino de la Cruz, Cipriano Aran, Celestina S. Mallari, and Rodolfo Rivera—all residents of Mambog, Binangonan, Rizal.
- Around October or November 1977, Mejorada contacted the claimants informing them he could process their claims for compensation.
- He required the claimants to sign blank copies of “Sworn Statement on the Correct and Fair Market Value of Real Properties” and “Agreement to Demolish, Remove and Reconstruct Improvements” without explaining their contents.
- The documents falsely inflated the valuations of the properties and improvements, with “Agreements to Demolish” reflecting values allegedly near those per assessor, but the underlying Declarations of Real Property were falsified or registered under other persons’ names.
- After processing, Mejorada accompanied claimants to receive payments at the Office of the Highway District Engineer and personally assisted in signing vouchers and encashing checks, certifying the identities, and guaranteeing payment.
- Upon receiving the compensation, Mejorada and an armed companion took the bulk of the proceeds, leaving only P1,000.00 to each claimant (except Isaac Carlos, who was left P5,000.00), citing that others would share the amounts.
- Claimants were fearful and unable to complain until they sought legal assistance and filed complaints with the Provincial Fiscal’s Office.
- Details of the Informations
- Eight informations were filed by the Provincial Fiscal against Mejorada, tried jointly in the Sandiganbayan.
- Each charged violation of Section 3(e) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act, alleging undue injury to claimants and the government through petitioner’s conduct.
- Criminal Case No. 002 detailed the scheme involving the claim of Isagani de Leon, where P7,200.00 was paid but only P1,000.00 was given to the claimant, and the rest was appropriated by the petitioner. The other seven informations mirrored this pattern with different dates, claimants, and amounts.
Issues:
- Whether the essential elements of violation under Section 3(e) of Republic Act No. 3019 were proven beyond reasonable doubt.
- Whether the Sandiganbayan had jurisdiction and was a court of competent jurisdiction legally constituted under President Decree No. 1606.
- Whether the penalty imposed on petitioner was excessive and contrary to the three-fold rule under Article 70 of the Revised Penal Code.
- Whether there was a variance between the offense charged in the informations and the offense proven at trial.
- Whether the conclusion of the Sandiganbayan convicting the petitioner was legally correct and subject to review by the Supreme Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)