Case Summary (G.R. No. 203382)
Procedural Background
The petitioners challenged the January 31, 2012 Decision and September 7, 2012 Resolution of the Sandiganbayan (SB), which found them guilty of violating Section 3(e) of Republic Act (R.A.) No. 3019, the Anti-Graft and Corrupt Practices Act, in Criminal Case No. SB-08-CRM-0019. The decision stemmed from an Information charging the petitioners for conspiring to demolish temporary shelters unlawfully erected by private complainants.
Facts of the Case
The case arose when private complainants, consisting of families from "Samahang Magkakapitbisig," were displaced from a parcel of land in Quezon City and sought relocation to a lot in Brgy. Burgos, purchased through a settlement agreement. Upon their attempt to relocate, Mayor Cuerpo imposed conditions regarding the need for development permits and building permits, which effectively prevented their relocation.
Despite applications for permits being processed, the petitioners took actions to demolish temporary shelters that the private complainants erected after vacating their previous location, without the necessary permits. The private complainants alleged that the demolition was conducted with evident bad faith, without due process, and without a court order, resulting in undue injury.
Sandiganbayan's Ruling
The SB found sufficient evidence of conspiracy among the petitioners, ruling that Cuerpo's instructions, combined with RoAo's justification for requiring development permits, demonstrated a coordinated effort to prevent the relocation of the private complainants. Simbulan's involvement in enforcing the demolition order aggravated the situation, as he confiscated possessions without any legal justification.
Elements of the Crime
To establish the violation under Section 3(e) of R.A. No. 3019, the prosecution must demonstrate that:
- The accused were public officers performing official functions.
- Their actions were marked by manifest partiality, evident bad faith, or gross negligence.
- The actions caused undue injury to the private complainants.
The Court upheld that the evidence showed the petitioners held public office and their collective actions led to evident bad faith, disregarding legal procedures for eviction and demolition, ultimately causing significant injury to the private complainants.
Petitioners' Defense and Court's Assessment
The petitioners argued that the demolitions were done in good faith, asserting they were enforcing safety by preventing construction without proper permits. The Court emphasized that while deficiencies in permits were present, this did not authorize summary demolition without due process. The Sandiganbayan’s conviction was affixed as there were no erroneous factual findings upon review.
Conclusion on the Appeal
The Supreme Court affirmed the San
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Background of the Case
- The case arises from a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- Petitioners include Mayor Pedro S. Cuerpo, Engr. Fernando H. RoAo, and Barangay Captain Salvador Simbulan, who were charged with violating Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
- The case stemmed from the demolition of temporary shelters belonging to private complainants, who were former informal settlers.
Factual Context
- Private complainants (Leticia B. Nanay, Nancy B. Barsubia, Gemma I. Bernal, Maria Victoria G. Ramirez, Crisanta S. Oxina, and Adelaida H. Ebio) were among 93 families from "Samahang Magkakapitbisig" who occupied land in Quezon City.
- To resolve their informal settlement status, they entered into an agreement to vacate the property for P2,250,000.00 in financial assistance.
- After finding land for relocation in Brgy. Burgos, Rodriguez, Rizal, the complainants sought to relocate but faced opposition from Mayor Cuerpo, who required them to obtain a development permit first.
Legal Proceedings and Actions Taken
- The private complainants filed a petition for Prohibition, Mandamus, and Damages due to the Mayor's refusal to grant relocation.
- The Regional Trial Court (RTC) denied their request for a temporary restraining order, ordering them to apply for building permits.
- Following the issuance of a Fifth Alias Writ of Demolit