Case Digest (G.R. No. 237172)
Facts:
Mario Joel T. Reyes v. People of the Philippines, G.R. No. 237172, September 18, 2019; Decision promulgated December 21, 2020, Supreme Court Third Division, Leonen, J., writing for the Court. Petitioner Mario Joel T. Reyes (then Governor of Palawan) challenged his conviction by the Sandiganbayan for violation of Section 3(e), Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act) and the Sandiganbayan’s revocation of his bail.Olympic Mines and Development Corporation (Olympic Mines) held mining lease contracts in Narra and Espanola, Palawan and granted Platinum Group Metal Corporation (Platinum Group) exclusive rights to operate portions of those leases. In 2004 Olympic Mines and Platinum Group were each issued Small Scale Mining Permits (SSMP PLW Nos. 37 and 39) permitting annual extraction of 50,000 dry metric tons (DMT) of laterite ore; the DENR issued Environmental Compliance Certificates (ECCs) likewise imposing a 50,000 DMT-per-year limit. Between May 30, 2005 and April 3, 2006, Platinum Group transported a combined total of 203,399.135 DMT under those permits.
On March 10, 2006, Olympic Mines applied to renew SSMP PLW No. 37. The Provincial Mining Regulatory Board (PMRB) unanimously recommended approval; on April 6, 2006, Governor Reyes approved and issued SSMP PLW No. 37.1 (April 6, 2006–April 5, 2008) authorizing another 50,000 DMT per year. After further transport activity, the DENR Secretary cancelled Olympic Mines’ ECC for over-extraction on September 25, 2006, but the Office of the President subsequently reversed that cancellation.
The Office of the Ombudsman filed Information charging petitioner and PMRB head Andronico J. Baguyo with violation of RA 3019, Sec. 3(e) for granting renewal despite alleged over-extraction and prohibited use of heavy equipment. After trial, on August 29, 2017 the Sandiganbayan convicted Reyes of Section 3(e) (sentenced to an indeterminate term of six years and one month to eight years with perpetual disqualification) but acquitted Baguyo. The Sandiganbayan concluded there was no manifest partiality or evident bad faith but found gross inexcusable negligence because Reyes approved renewal while extraction limits had been exhausted and failed to impose sanctions for use of heavy machinery. Reyes’ motion for reconsideration was denied on January 25, 2018.
Petitioner filed a Petition for Review on Certiorari under Rule 45, assailing the conviction and separately filed an Urgent Motion to Review the Revocation of Bail contesting the Sandiganbayan’s January 17, 2018 Resolution cancelling his bail on grounds of prior violations of bail conditions and probability of flight. The prosecution relied on Ore Transport...(Subscriber-Only)
Issues:
- Did the Sandiganbayan err in convicting petitioner Mario Joel T. Reyes of violation of Section 3(e), RA 3019, for approving the renewal of Olympic Mines’ Small Scale Mining Permit?
- Did the Sandiganbayan err in revoking petitioner’s bail on the grounds of violation of bail conditions and...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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