Title
Cruz vs. People
Case
G.R. No. 197142
Decision Date
Oct 9, 2019
A 1986 ejectment case led to obstruction claims against petitioners, including a mayor, for delaying writ enforcement. Supreme Court acquitted due to lack of conspiracy evidence and failure to prove graft charges.

Case Summary (G.R. No. 197142)

Petitioners, Respondent and Roles

Petitioners were municipal officials accused of conspiring and using their official positions to obstruct enforcement of court-issued writs (writs of execution and demolition) in favor of a private person (Alex Halili), thereby allegedly committing violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The People prosecuted them before the Sandiganbayan; the case reached the Supreme Court by petitions for review on certiorari.

Key Dates and Procedural Landmarks (chronology)

  • MTC judgment in Civil Case No. 1526: decision in favor of plaintiffs rendered November 17, 1989; judgment became final December 27, 1989 and entirely enforceable December 27, 1990.
  • Post-judgment enforcement and writs: motions for writs and multiple alias writs of execution and demolition issued thereafter; enforcement difficulties led to several alias writs.
  • Alleged obstruction incident: March 5, 1993 (implementation of the fourth alias writ of execution and third alias writ of demolition).
  • Sandiganbayan: Decision convicting petitioners dated September 10, 2008; Resolution denying reconsideration dated May 30, 2011.
  • Supreme Court disposition: appeal of Sandiganbayan judgment resolved by the Court (decision referenced herein relied on applicable post-1990 law).

Applicable Law and Constitutional Basis

  • Governing constitution: the 1987 Philippine Constitution (applicable because the decision was rendered after 1990).
  • Penal and procedural provisions referenced: Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) — proscribing a public officer who gives any private party unwarranted benefits, advantage or preference through manifest partiality, evident bad faith or gross inexcusable negligence; Article 89 of the Revised Penal Code (extinguishment of liability by death of an accused); the Indeterminate Sentence Law; and relevant rules on criminal procedure and standards of proof (proof beyond reasonable doubt).
  • Controlling evidentiary and doctrinal principles: requirements to establish conspiracy (agreement, unity of purpose and overt acts), and definitions/standards for "manifest partiality," "evident bad faith," and "gross inexcusable negligence" as applied in RA 3019 jurisprudence.

Factual Background (civil origin and enforcement attempts)

The dispute originated from Civil Case No. 1526 (ejectment) filed by Ma. Rosario Batongbacal and co-plaintiffs against spouses Marcelo and Amelia Del Rosario. After final judgment in favor of plaintiffs and repeated unsuccessful enforcement attempts, several alias writs of execution and demolition were issued to enforce possession and effect demolition of structures on the property. Repeated enforcement efforts encountered resistance; plaintiffs alleged that on March 5, 1993 the enforcement of the relevant alias writs was obstructed by the petitioners and others.

Criminal Information and Pre-trial Stipulations

The Information charged petitioners with conspiring to obstruct enforcement of court writs and thereby causing undue injury and conferring unwarranted benefits to Alex Halili, contrary to Section 3(e) of R.A. No. 3019. Pre-trial stipulations included recognition of the official positions of the accused at or about March 5, 1993, the presence of Civil Case No. 774-M-94 (a separate proceeding), the issuance dates of the second alias writs, and that Judge Ortiguerra had issued an order dated March 5, 1993 holding in abeyance implementation of the writ of demolition. The building was eventually demolished in 1995; however the prosecution did not establish specific quantifiable damages attributable to the alleged obstruction.

Prosecution Evidence and Witnesses

The prosecution presented, among others, the private complainant Atty. Batongbacal and officers involved in enforcement: Sheriffs Villarente and Pagulayan, and process server Aligato. Key points of prosecution testimony were: (1) repeated failure to fully enforce writs due to intervention from petitioners and associates; (2) that petitioners and companions (identified by Pagulayan and Aligato) physically intervened at the demolition site, ordered or induced stoppage, threatened enforcement personnel and caused sheriff(s) and process personnel to be brought to the municipal building; (3) that Alexander Halili’s structure was included in the demolition at one point and that petitioners advocated on Halili’s behalf. The prosecution emphasized the presence and actions of petitioners at the scene and the consequent inability to fully execute the writs.

Defense Evidence and Testimony

Petitioners and their witnesses testified that they acted in the ordinary discharge of municipal duties and to protect the interests of a constituent (Halili) who claimed the structure was not subject to the demolition order. The defense version emphasized: (1) petitioners escorted Halili to the sheriff and asked for clarification; (2) they invited the sheriffs to attend a conference with Judge Ortiguerra to resolve the boundary dispute and scope of the writ; (3) petitioners did not order violent obstruction; there was no evidence of firearms used by them and no contempt citation against petitioners by the judge; and (4) an order by Judge Ortiguerra dated March 5, 1993 held the demolition in abeyance in order to identify the exact lot and structures to be demolished, an operative judicial act that explains why enforcement ceased.

Sandiganbayan’s Findings and Conviction

The Sandiganbayan limited the legal issue to whether petitioners’ actions in preventing enforcement caused undue injury or gave unwarranted benefits. It concluded that, except for Aspuria, petitioners Dela Cruz, Cruz and Carpio conspired to give Alex Halili unwarranted benefits by interfering and obstructing enforcement of the writs. The tribunal found “evident bad faith” in their conduct and imposed an indeterminate prison sentence (6 years and 1 month to 10 years) on each convicted petitioner. Mauricio’s case was dismissed upon his death; Aspuria was acquitted for insufficiency of evidence. The Sandiganbayan denied the petitioners’ motions for reconsideration.

Issues on Appeal to the Supreme Court

The consolidated petitions raised two principal issues: (1) whether the Sandiganbayan erred in finding a conspiracy among petitioners to commit the offense; and (2) whether the Sandiganbayan erred in finding petitioners guilty of violating Section 3(e) of RA 3019.

Legal Standards Applied on Appeal (conspiracy, Section 3(e), proof beyond reasonable doubt)

The Supreme Court reiterated established standards: conspiracy requires an agreement among two or more persons concerning commission of a felony, with proof beyond reasonable doubt of specific acts by each participant indicating unity of purpose and a conscious community of design. Mere presence, companionship, knowledge, acquiescence or passive assistance are insufficient to establish conspiracy. For conviction under Section 3(e) of RA 3019, prosecution must prove (1) accused is a public officer performing official functions; (2) action was with manifest partiality, evident bad faith or gross inexcusable negligence; and (3) the action conferred unwarranted benefits, advantage or preference to a private party. The Court also reiterated the definitions of these mental states: manifest partiality is a clear, notorious inclination to favor; evident bad faith connotes a palpably fraudulent, dishonest purpose or moral obliquity; gross inexcusable negligence denotes want of even the slightest care.

Supreme Court’s Analysis of the Evidence and Misappreciation by the Sandiganbayan

The Court found that the Sandiganbayan’s conclusory statements of conspiracy lacked specificity: it did not identify overt acts by each petitioner demonstrating a unity of purpose or common design to confer unwarranted benefits to Halili. The prosecution’s evidence largely established presence of Cruz and Carpio at the demolition site and municipal hall, and that they accompanied Mayor Dela Cruz and Halili to seek clarification; such acts, without more, do not constitute overt acts in furtherance of a conspiratorial design. The Court emphasized that the prosecution failed to prove intentional participation in a common criminal design with the requisite moral certainty. The Court also noted and relied upon (and found the Sandiganbayan had overlooked) Sheriff Pagulayan’s testimony that he would not stop demolition without a court order and upon the Judge Ortiguerra’s March 5, 1993 Order holdin

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