Case Summary (G.R. No. 248971)
Procedural History
This case is a Petition for Review on Certiorari under Rule 45 of the 1997 Revised Rules of Civil Procedure aimed at reversing decisions made by the Court of Appeals regarding the orders of the Regional Trial Court (RTC) of Calamba City. The RTC originally found probable cause to issue a warrant of arrest against Atty. FandiAo and others for violations of the anti-graft law. The Court of Appeals subsequently annulled these orders.
Audit Findings
An audit conducted by COA found that CWD, from 1993 to 2001, inappropriately granted substantial benefits and allowances exceeding legal limits. This was documented in COA Report No. 2002-06, which concluded that the compensation granted to board members was unauthorized according to Section 13 of Presidential Decree No. 198. Recommendations were made for the reevaluation of these benefits and stricter compliance with applicable laws.
Ombudsman Complaint
Following the COA findings, Catindig filed a complaint with the Office of the Ombudsman alleging gross violation of anti-graft laws against Atty. FandiAo and other board members. The Ombudsman later recommended criminal charges under Section 3(e) of Republic Act No. 3019, citing probable cause based on the COA's findings, leading to the filing of two Informations against the accused.
RTC Orders
The RTC issued an order finding probable cause for the issuance of arrest warrants against FandiAo and his co-accused. It also ordered their suspension from office for 60 days pending the outcome of the trial. Motions for reconsideration filed by the accused were denied.
Court of Appeals Decision
Atty. FandiAo filed a certiorari petition with the Court of Appeals, which found that the RTC orders were issued with grave abuse of discretion. The Court of Appeals ruled that the applicants received the disputed allowances in good faith, making it impossible to establish elements of bad faith or negligence required for a violation of Section 3(e) of Republic Act No. 3019.
Assignment of Errors
Catindig's appeal presented multiple claims of error by the Court of Appeals, arguing that it overstepped its jurisdiction by ruling on facts rather than procedure and improperly failed to dismiss the Petition based on res judicata, among other issues.
Supreme Court Rulings
The Supreme Court affirmed the decision of the Court of Appeals, stating that there was no probable cause to prosecute the respondents and no basis to sustain the issuance of arrest warrants. It highlighted that the acts attributed to Atty. FandiAo and others did not reflect manifest partiality or evident bad faith, as they acted under the belief that previous resolutions from the LWUA were va
...continue readingCase Syllabus (G.R. No. 248971)
Case Overview
- Court: Supreme Court of the Philippines
- Date: September 18, 2009
- G.R. No.: 183141
- Petitioner: Edgardo H. Catindig
- Respondents: The People of the Philippines and Atty. Daniel P. FandiAo, Jr.
- Nature: Petition for Review on Certiorari under Rule 45 of the 1997 Revised Rules of Civil Procedure
Background of the Case
- The case arises from a Petition for Review on Certiorari seeking to annul the Decision dated September 14, 2007, and the Resolution dated May 14, 2008, of the Court of Appeals in CA-G.R. SP No. 96293.
- The Court of Appeals annulled two Orders from the Regional Trial Court (RTC) of Calamba City regarding Criminal Case No. 13850-05-C, which involved allegations against Atty. Daniel P. FandiAo and others for violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
Factual Antecedents
- In 2001, the Commission on Audit (COA) audited the Calamba Water District (CWD) to assess the legality of water rate increases.
- The audit revealed that the CWD Board of Directors granted unauthorized benefits totaling P15,455,490.14, including excessive allowances and benefits beyond legal limits as per Presidential Decree No. 198.
- The COA's findings indicated violations of the law, notably that members of the Board were not entitled to compensation beyond per diems.
Legal Proceedings
- On July 7, 2004, Edgardo H. Catindig filed a c