Case Summary (G.R. No. 94955)
Background of the Case
The charges against Coronado stem from his failure to serve a court order from July 11, 1984, in Civil Case No. 290-A, which had implications for the plaintiffs and defendants in the case. The initial Information was filed on November 26, 1985, but subsequent arraignments were postponed due to ongoing reinvestigations. On September 23, 1987, the Sandiganbayan permitted an amended Information to be filed against Coronado, indicating his alleged neglect in serving the court’s order within a reasonable timeframe, thus favoring the plaintiffs by prolonging the litigation process.
Summary of Events
The Sandiganbayan detailed a sequence of events relevant to the case. Initially, an order was issued by the RTC denying the plaintiffs' motion for reconsideration on January 23, 1984. The order was not served timely, leading to complaints from Mariano Lim, a defendant in the civil case, who expressed concerns about the delay. Coronado made two unsuccessful attempts to serve the order before it was ultimately delivered on February 22, 1985, resulting in a five-month delay. Lim's subsequent inquiries revealed problems with the service process, contributing to the charges against Coronado.
Legal Standpoint on Charges
The central question posed is whether Coronado's failure to execute the service of a court order constitutes a violation of the Anti-Graft and Corrupt Practices Act as defined in Section 3(f). This section identifies corrupt practices, including neglecting or refusing to act without sufficient justification after due demand is made. The elements required for conviction include Coronado's status as a public officer, his neglect or refusal to act, a reasonable time lapse since the demand, and a motive of obtaining benefit for another party or discrimination against an interested party.
Analysis of the Fourth Element
While the first three elements of the offense were established, contention arose regarding the fourth element, which necessitates the demonstration of intent to secure a benefit or discriminate against another. The Sandiganbayan found that although Coronado demonstrated neglect, there was no evidence suggesting that his delays stemmed from intent to derive personal gain or favor one party over another. This abs
...continue readingCase Syllabus (G.R. No. 94955)
Case Background
- The case revolves around Juan Coronado, who was convicted by the Sandiganbayan for violating Section 3(f) of Republic Act No. 3019, the Anti-Graft and Corrupt Practices Act.
- Coronado was employed as a Process Server in the Office of the Clerk of Court of the Regional Trial Court (RTC) of Antipolo, Rizal.
- He, along with two others, was charged in connection to a civil case involving the Pinagkamaligan Indo-Agro Development Corporation and Mariano Lim.
- An Information dated November 26, 1985, initiated the criminal proceedings against Coronado.
- The arraignment was delayed multiple times due to a pending reinvestigation by the Tanodbayan, which eventually led to an amended Information against Coronado being filed.
Factual Circumstances Leading to the Charge
- The original order in question was issued by Executive Judge Antonio V. Benedicto on July 11, 1984, denying a motion for reconsideration in Civil Case No. 290-A.
- Despite demands from Mariano Lim, one of the defendants in the civil case, for the Order to be served, it was not delivered promptly.
- Coronado attempted to serve the Order on two occasions: first, he could not locate the address for Atty. Patrocinio Palanog; the second attempt was unsuccessful as Atty. Palanog was not home.
- The Order was ultimately served on February 22, 1