Case Digest (G.R. No. 252258)
Facts:
People of the Philippines v. Richard R. Enojo, G.R. No. 252258, April 06, 2022, Supreme Court Second Division, Hernando, J., writing for the Court.The People (plaintiff-appellee) charged accused-appellant Atty. Richard R. Enojo (Enojo), then Provincial Legal Officer of Negros Oriental, with violating Section 3(a) of Republic Act No. 3019 (Anti‑Graft and Corrupt Practices Act) in an Information dated December 27, 2017. The Information alleged that on or about February 7, 2013 (or thereabouts) Enojo, taking advantage of his office, persuaded the Dauin Police to summon certain persons to a conference regarding a land dispute, thereby inducing police to act beyond their mandate under Section 24 of Republic Act No. 6975 (DILG Act of 1990).
The underlying property dispute began with a Deed of Absolute Sale dated January 15, 2013 whereby Dauin Point Land Corporation (DPLC), represented by Director Ligaya S. Rubio‑Violeta, purchased Lot No. 394 from Ramon Regalado, represented by his attorney‑in‑fact Merlinda A. Regalado; Ralph Gavin Hughes (Hughes) was a DPLC stockholder who applied for a fencing permit. While Hughes’s application was pending, Enojo sent a February 28, 2013 letter claiming a portion of Lot 394 as payment for legal services and opposing the fencing permit; the Municipal Planning and Development Coordinator (Sanchez) referred the matter upward and DILG Region 7 advised on April 24, 2013 that Enojo’s opposition was unsubstantiated and that the locational clearance should be issued, after which the locational clearance was in fact issued.
On February 27, 2013 Enojo went to the Dauin Police Station and requested a conference with Hughes, Violeta and Regalado. Senior Police Officer 4 Proculito A. Briones (SPO4 Briones), the station’s designated chief investigator, recorded the request in the police blotter and transmitted a radio message to Dumaguete City Police Station inviting the named persons to a conference at the Dauin Police Station on March 1, 2013. Aggrieved, Hughes (for DPLC) filed criminal and administrative complaints on November 16, 2015 with the Office of the Ombudsman; the Ombudsman found probable cause for violation of Section 3(a) of RA 3019 on May 26, 2017 and ordered the filing of an Information, which was lodged with the Sandiganbayan on February 9, 2018.
After arraignment (May 25, 2018), pretrial and trial, the Sandiganbayan by Decision dated October 18, 2019 convicted Enojo of Section 3(a) of RA 3019, sentencing him to an indeterminate term of six years and one month to ...(Pro-only)
Issues:
- Whether accused‑appellant Richard R. Enojo was proven guilty beyond reasonable doubt of violating Section 3(a) of RA 3019...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)