Title
People vs. Enojo
Case
G.R. No. 252258
Decision Date
Apr 6, 2022
Public official acquitted of graft charges as prosecution failed to prove he influenced police to act beyond duties in a land dispute.
A

Case Digest (G.R. No. 881)

Facts:

  • Parties and Procedural History
    • The People of the Philippines (plaintiff-appellee) charged Atty. Richard R. Enojo (accused-appellant) with violation of Section 3(a) of RA 3019 before the Sandiganbayan in Criminal Case No. 18-CRM-0122.
    • After arraignment and trial, the Sandiganbayan found Enojo guilty, sentenced him to six years and one month to eight years imprisonment with perpetual disqualification from public office, and denied his motions for reconsideration and to reopen the case.
  • Underlying Land Dispute
    • On January 15, 2013, Dauin Point Land Corporation (DPLC) acquired Lot 394 in Dauin, Negros Oriental by Deed of Absolute Sale from Ramon Regalado.
    • DPLC’s stockholder Ralph Gavin Hughes applied for a fencing permit; the Municipal Planning and Development Coordinator (Sanchez) sought guidance from DILG Region 7, which found DPLC’s claim of ownership properly supported.
  • Enojo’s Intervention and Police Involvement
    • On February 28, 2013, Enojo wrote to Sanchez opposing the fencing permit, claiming part-ownership of Lot 394 for legal fees.
    • On February 27, 2013, Enojo requested SPO4 Proculito Briones of Dauin Police Station to summon Hughes, Merlinda Regalado, and Atty. Ligaya Rubio-Violeta for a conference regarding the land dispute; Briones recorded the request and sent a radio message to Dumaguete City Police Station.
  • Complaints and Ombudsman Resolution
    • Hughes and DPLC filed criminal and administrative complaints on November 16, 2015 before the Office of the Ombudsman for violation of Section 3(a), (e), and (h) of RA 3019.
    • On May 26, 2017, the Ombudsman found probable cause for Section 3(a) only and dismissed (e) and (h) for lack of evidence; the Information was subsequently filed with the Sandiganbayan.
  • Sandiganbayan Decision
    • On October 18, 2019, the Sandiganbayan convicted Enojo for having “persuaded, induced or influenced” the police to commit an act beyond their powers under Section 24 of RA 6975.
    • The appellate resolution denying reconsideration was promulgated on January 2, 2020.

Issues:

  • Whether Atty. Richard R. Enojo is guilty beyond reasonable doubt of violating Section 3(a) of RA 3019 for persuading, inducing, or influencing a public officer to perform an act contrary to law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.