Case Summary (G.R. No. 187858)
Facts and Procedural History
The events leading up to the case began with an ejectment complaint filed in 1986 by Maria Rosario Batongbacal and others against Marcelo L. Del Rosario and his spouse. Following a favorable judgment for the plaintiffs, multiple writs of execution and demolition were issued but faced persistent obstruction. On March 5, 1993, Cruz, Dela Cruz, Carpio, and others reportedly interfered with the execution of these writs. This led to a complaint lodged by Atty. Mario A. Batongbacal with the Office of the Ombudsman, resulting in the indictment of the petitioners.
Prosecution's Case
The prosecution presented several witnesses, including Atty. Batongbacal, various Sheriffs, and others involved in the attempted demolition. They testified about the obstruction of the demolition process purportedly instigated by the petitioners, detailing incidents where the sheriffs and demolition team were prevented from carrying out their duties by Mayor Dela Cruz and his associates. The prosecution argued that there was evident conspiracy and bad faith among the petitioners that disadvantaged the plaintiffs while providing unwarranted benefits to others, particularly a person named Alexander Halili.
Defense’s Argument
The defense focused on the lack of conspiracy, asserting that the petitioners acted within the scope of their responsibilities as public officials. Cruz and Dela Cruz denied actively preventing the court's orders and instead maintained that they were present to clarify property ownership issues, purportedly acting in their constituents' interests. Testimonies from petitioners contended that the sheriffs, rather than the mayor, ordered the demolition to cease.
Sandiganbayan's Decision
The Sandiganbayan found Cruz and Dela Cruz guilty of violating Section 3(e) of RA 3019, sentencing them to imprisonment ranging from six years and one month to ten years. The court ruled there was sufficient evidence showing they obstructed the court's legal processes, which resulted in undue benefits to a private party through their actions, showcasing evident bad faith and manifest partiality.
Supreme Court’s Ruling
Upon appeal, the Supreme Court addressed the implications of Dela Cruz's death during the proceedings, ultimately concluding that this extinguished his criminal liability. The court explained that Dela Cruz’s death rendered the Sandiganbayan’s judgment against him ineffectual. The Court then examined the cases of Cruz and Carpio, finding that the prosecution failed to prove their culpabil
...continue readingCase Syllabus (G.R. No. 187858)
Case Citation
- G.R. No. 197142, October 09, 2019
- G.R. No. 197153, October 09, 2019
Court and Decision
- Second Division of the Supreme Court of the Philippines
- Decision authored by Justice Caguioa
Parties Involved
- Petitioners:
- Gil "Boying" R. Cruz
- Serafin N. Dela Cruz (former Mayor)
- Dennis C. Carpio
- Respondent: The People of the Philippines
Background of the Case
- The consolidated Petitions for Review on Certiorari challenge the Decision dated September 10, 2008, and the Resolution dated May 30, 2011, from the Sandiganbayan, which found the petitioners guilty of violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
- The petitioners were sentenced to imprisonment ranging from six (6) years and one (1) month to ten (10) years.
Facts and Antecedent Proceedings
- Initial Complaint:
- An ejectment complaint was filed on October 22, 1986, by Maria Rosario Batongbacal and others against Marcelo L. Del Rosario and Amelia V. Del Rosario for a property dispute, leading to Civil Case No. 1526.
- Judgment and Enforcement:
- The Municipal Trial Court (MTC) ruled in favor of the plaintiffs on November 17, 1989, with the judgment becoming enforceable on December 27, 1990.
- A series of alias writs of execution and demolition were issued due to difficulties in enforcement.
- Incident of March 5, 1993:
- Petitioners Cruz, Mayor Dela Cruz, and Carpio, along with others, allegedly obstructed the enforcement of the court's order regarding the demolition of an illegally constructed structure.
- Ombudsman Complaint:
- Atty. Mario A. Batongbacal, on behalf of the plaintiffs, filed a complaint with the Office of the Ombudsman against the petitioner