Case Digest (G.R. No. 150194)
Facts:
Robert Tayaban y Caliplip, Francisco Maddawat y Tayoban, Artemio Balangue y Langa, Francisco Mayumis y Bahel and Quirino Pana y Cuyahen v. People of the Philippines and the Honorable Sandiganbayan, G.R. No. 150194, March 06, 2007, Supreme Court Third Division, Austria‑Martinez, J., writing for the Court.Petitioners were municipal officials of Tinoc, Ifugao: Robert Tayaban was Municipal Mayor; Francisco Maddawat, Artemio Balangue, Francisco Mayumis and Quirino Pana were members of the Sangguniang Bayan. Private complainant Lopez Pugong was the contractor who won the contract to build the Tinoc Public Market, the project having been approved and funded by the Cordillera Executive Board (CEB). The CEB, under E.O. No. 220, was the project owner and had entered into a formal contract with Pugong on March 1, 1989; construction started in June 1989.
On August 15, 1989 the Sangguniang Bayan of Tinoc adopted Resolution No. 20, which resolved to demolish the structures erected on the site. On that same day petitioners and several men proceeded to the site and demolished five concrete posts and other improvements. Pugong filed an Affidavit‑Complaint, and on June 26, 1992 an Information was lodged charging petitioners with violation of Section 3(e) of R.A. No. 3019 (Anti‑Graft and Corrupt Practices Act). Petitioners pleaded not guilty at arraignment and were tried before the Sandiganbayan.
After trial the Sandiganbayan rendered judgment on June 25, 2001 convicting all accused of violating Section 3(e) of R.A. No. 3019 and sentenced them under the Indeterminate Sentence Law to imprisonment and indemnity (joint and several payment of P134,632.80). The Sandiganbayan denied petitioners’ motion for reconsideration by Resolution dated September 28, 2001. Petitioners filed a Petition for Review on Certio...(Subscriber-Only)
Issues:
- Did the prosecution prove the elements of a violation of Section 3(e) of R.A. No. 3019 — specifically, that petitioners acted with manifest partiality, evident bad faith or gross inexcusable negligence and that their actions caused undue injury to the Government or a private party?
- Were petitioners entitled to rely on Resolution No. 20, the Local Government Code provisions, P.D. No. 1096, or LOI No. 19 (or the exercise of police power) to justify the demolition?
- Did the Sandiganbayan err in its evaluation of evidence and credibility (notably of witness Abe Belin...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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