G.R. No. 122058 - Bunye vs. Sandiganbayan

Parties Involved: Petitioners are Ignacio R. Bunye, Jaime R. Fresnedi, Carlos G. Tensuan, Roman E. Niefes, Roger C. Smith, Rufino B. Joaquin, Nolasco L. Diaz, and Rufino Ibe. Respondents include the Sandiganbayan (Second Division), the People of the Philippines, and Kilusang Bayan sa Paglilingkod ng mga Magtitinda sa Bagong Pamilihang Bayan ng Muntinlupa, Inc. (KBMBPM).
Case Number: Criminal Case No. 13966
Court: Supreme Court of the Philippines
Date of Decision: May 05, 1999

Legal Provision: Section 3(e) of R.A. No. 3019, known as the Anti-Graft and Corrupt Practices Act.
Charges: Petitioners, all public officers, were accused of unlawfully taking possession of the New Public Market in Muntinlupa despite an existing lease contract.

Public Officers: Individuals holding positions in government, responsible for public duties.
Undue Injury: Harm caused to a party without just cause, leading to potential damages.

Petitioners enacted "Kapasiyahan Bilang 45" and took over the operation of the public market while a valid lease existed.
They ignored warnings from higher authorities to take legal steps to annul the lease.

Lease Contract Date: September 2, 1985, valid for 25 years, renewable for another 25 years.
Monthly Rental: P35,000, significantly lower than market income.
Cooperative Investment: KBMBPM invested P13,479,900 in improvements.

Initial Motion: Petitioners filed a Motion to Dismiss based on a previous Court of Appeals decision.
Sandiganbayan's Ruling: Denied the motion, leading to a trial where petitioners were found guilty.

Conviction: Petitioners were sentenced to 6 years and 1 month to 10 years and 1 day imprisonment, along with an indemnity of P13,479,900 to KBMBPM.

Unconstitutionality of Lease: Petitioners claimed the lease was void and did not require court action for its cancellation.
Validity of Kapasiyahan Bilang 45: They argued it was entitled to presumption of constitutionality and obedience.
Lack of Evidence for Guilt: They contended that no undue injury or benefits were created from their actions.

The Court found insufficient evidence to prove guilt beyond a reasonable doubt.
The lease was determined to be grossly disadvantageous but not null and void.
The absence of undue injury to KBMBPM was emphasized, as no market vendor was adversely affected.

Legal Interpretation: The Court noted that unilateral revocation of contracts without due process or court intervention was improper.
Evidence Evaluation: The lack of concrete evidence regarding damages led to the acquittal of petitioners.

The Supreme Court ruled in favor of the petitioners, acquitting them due to insufficient evidence of guilt regarding the alleged anti-graft violations.
The decision underscores the necessity for public officers t...continue reading