Case Digest (G.R. No. 214054)
Facts:
People of the Philippines v. Sandiganbayan (Fourth Division), Jessie Castillo, Melencio Arciaga and Emerenciano Arciaga, G.R. No. 160619, September 09, 2015, Supreme Court Third Division, Jardeleza, J., writing for the Court.
The petition under Rule 45 was filed by the People of the Philippines through the Office of the Special Prosecutor seeking reversal of the Sandiganbayan Resolutions dated January 9, 2002 and November 3, 2003 which, respectively, granted private respondent Jessie B. Castillo’s Supplemental Motion to Quash an Information and denied the People’s motion for reconsideration.
In May 1998 Castillo was elected Mayor of Bacoor, Cavite. On September 19, 2000 an Information was filed charging Castillo with violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), alleging that, while acting in his official capacity, Castillo gave unwarranted benefits to Melencio and Emerenciano Arciaga by allowing operation of the Villa Esperanza dumpsite without an Environmental Compliance Certificate or EMB permit and despite DENR cease-and-desist orders, thereby causing undue injury to nearby residents and students.
An administrative complaint for simple misconduct arising from the same facts had earlier been filed with the Office of the Ombudsman; the Ombudsman imposed a one-month-and-one-day suspension, but the Court of Appeals set aside that administrative penalty and dismissed the administrative complaint on appeal. After arraignment and pre-trial in the criminal case, Castillo filed a Motion to Dismiss or Terminate Proceedings (August 21, 2001), which the Sandiganbayan Fourth Division initially denied by Resolution dated September 6, 2001. Castillo then filed a Supplemental Motion to Quash (September 21, 2001) arguing, inter alia, that the Information failed to state the extent of undue injury and the amount of unwarranted benefit as required by precedent.
Because the Fourth Division failed to act unanimously, a Special Division of five Sandiganbayan justices was constituted under Administrative Order No. 278-2001. By a 3–2 vote the Special Division granted Castillo’s Supplemental Motion in a January 9, 2002 Resolution, holding that the Information did not specify or quantify the alleged amount colle...(Subscriber-Only)
Issues:
- Must an Information charging violation of Section 3(e) of R.A. No. 3019 allege with precision the exact amount of the alleged unwarranted benefit and specify, quantify, and prove the alleged undue injury "to the point of moral certainty" at the pleading stage?
- Was the Sandiganbayan correct in quashing the Information outright instead of ordering amendment under the Rules of Court when ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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