Case Digest (G.R. No. 209099-100) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Gil A. Valera v. People of the Philippines, petitioner Gil A. Valera, a public official, was charged before the Sandiganbayan in four consolidated criminal cases (SB-11-CRM-0013 to ‑0016). On August 22, 2013, the Sandiganbayan found him guilty of violating Section 8 of Republic Act No. 6713 for omitting his wife’s P12,500 share in Buy Pinoy Marketing, Inc. and his minor daughter’s P27,000 share in MJ Valera Realty from his 2001 and 2003 Statements of Assets, Liabilities, and Net Worth (SALNs). The court imposed a ₱5,000 fine and disqualification from public office in Criminal Case Nos. SB-11-CRM-0013 and SB-11-CRM-0015, while acquitting him in SB-11-CRM-0014 and SB-11-CRM-0016 due to reasonable doubt. His Motion for Partial Reconsideration, filed but not set for hearing, was denied by Resolution dated September 18, 2013. Petitioner then filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, contending that a violation of RA 6713 is malum in se requirin Case Digest (G.R. No. 209099-100) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Cases
- Four separate Informations were filed in the Sandiganbayan against petitioner Gil A. Valera:
- Criminal Case No. SB-11-CRM-0016 for Falsification of Public Document.
- Criminal Case Nos. SB-11-CRM-0013, SB-11-CRM-0014, SB-11-CRM-0015 for violation of Section 8, RA No. 6713 (failure to disclose assets in SALN).
- The Sandiganbayan consolidated and tried all cases together.
- Trial Court Disposition
- Acquittal in SB-11-CRM-0014 and SB-11-CRM-0016 due to reasonable doubt.
- Conviction in SB-11-CRM-0013 and SB-11-CRM-0015 for omission of:
- Wife’s P12,500 stockholding in Buy Pinoy Marketing, Inc. (2001 SALN).
- Minor daughter’s P27,000 stockholding in MJ Valera Realty (2003 SALN).
- Penalty imposed: Fine of ₱5,000 and disqualification to hold public office.
- Post-Judgment Proceedings
- Petitioner filed a Motion for Partial Reconsideration, which the Sandiganbayan denied for failure to set the motion for hearing.
- Petitioner elevated the case to the Supreme Court via Petition for Review on Certiorari.
- Office of the Special Prosecutor (OSP) filed a Comment asserting finality of the Sandiganbayan Decision, characterizing RA 6713 violations as malum prohibitum, and upholding disqualification penalty.
Issues:
- Can the Supreme Court grant relief despite petitioner’s procedural lapse in setting the motion for hearing?
- Whether a violation of Section 8, RA No. 6713 is malum in se or malum prohibitum, and if intent or good faith matters.
- Whether petitioner was denied his right to avail of the review and compliance procedure under RA No. 6713 before sanction.
- Whether Section 11 of RA No. 6713 requires prosecution under a heavier-penalty law (falsification) instead of RA 6713.
- Whether the penalty of disqualification to hold public office was improperly imposed or too harsh.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)