G.R. No. 159611 - Heirs of Soliva vs. Soliva

Case Summary (G.R. No. 159611)

Factual Background

On January 5, 1979, Jaravata informed classroom teachers that the salary differentials for 1978 had been approved for release. To facilitate payment, Jaravata agreed to follow up the necessary papers in Manila; the teachers agreed to reimburse his expenses. Jaravata incurred P220.00 in expenses and divided this amount among six teachers at P36.00 each. After the teachers received their salary differentials, four teachers (Lopez, Dacayanan, Dulay, Bautista) paid Jaravata amounts greater than P36.00: Lopez P100.00, Dacayanan P118.00, Dulay P70.00, Bautista P50.00. The administrator Baltazar later ordered Jaravata to return the money given by those four teachers, and Jaravata complied and refunded the amounts.

Charges and Trial Court Disposition

Jaravata was charged with violating Section 3(b) of R.A. No. 3019 for allegedly, by virtue of his position and influence as assistant principal, demanding and receiving payments from certain classroom teachers in connection with the release of their salary differentials. The Sandiganbayan found him guilty beyond reasonable doubt and sentenced him to indeterminate imprisonment of one to four years, perpetual special disqualification from public office, and costs. No civil liability was pronounced because the money had been refunded.

Statutory Provision at Issue

Section 3(b) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) proscribes a public officer from directly or indirectly requesting or receiving any gift, present, share, percentage, or benefit for himself or for any other person “in connection with any contract or transaction between the Government and any other party, wherein the public officer in his official capacity has to intervene under the law.”

Legal Issue Presented

Whether, on the recorded facts, Jaravata violated Section 3(b) of R.A. No. 3019 — specifically, whether he, as assistant principal, received benefits “in connection with any contract or transaction between the Government and any other party, wherein [he] in his official capacity has to intervene under the law.”

Sandiganbayan’s Findings of Fact

The Sandiganbayan found as fact that: (1) the teachers were employees of the school with Jaravata as assistant principal; (2) Jaravata agreed to follow up the release of salary differentials in Manila and incurred expenses of P220.00; (3) the teachers agreed to reimburse him at P36.00 each; and (4) four teachers paid Jaravata amounts exceeding P36.00, resulting in an excess total of P194.00. The trial court concluded these excess receipts constituted unlawful benefit-taking under R.A. No. 3019.

Supreme Court’s Legal Analysis

The Supreme Court’s analysis focused on the statutory phrase “wherein the public officer in his official capacity has to intervene under the law.” The Court construed Section 3(b) to reach only those instances where the public officer’s official intervention in the particular contract or transaction is required by law. The pivotal question was whether Jaravata, by virtue of his official position, was legally required to intervene in the payment process for the teachers’ salary differentials. The Court found no statute or legal provision that vested the assistant principal with authority to intervene in the payment of salary differentials. Jaravata’s actions were characterized as voluntary facilitation or supplication to expedite payment rather than the exercise of a statutory or official power.

Application of Law to Facts

Because Jaravata was not legally empowered or required by law to intervene in the transaction of releasing salary differentials, his facilitation did not fall within the class of conduct proscribed by Section 3(b). Although amounts received in excess of P36.00

Case Syllabus (G.R. No. 159611)

Procedural History

Petition to review the decision of the Sandiganbayan in Criminal Case No. 873 was filed by Hilario Jaravata.
Case cited as 212 Phil. 338 EN BANC, G.R. No. L-56170, decided January 31, 1984.
The Sandiganbayan rendered a conviction for violation of Section 3(b) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
The Supreme Court petition raised factual and legal issues; the Court expressly limited its consideration to the legal issue only.

Parties and Roles

Petitioner: Hilario Jaravata, at the time the Assistant Principal of the Leones, Tubao, La Union Barangay High School.
Respondents: The Honorable Sandiganbayan and the People of the Philippines.
Other relevant school official: Conrado Baltazar, identified as the administrator.
Complainants / alleged payors: classroom teachers Ramos, Lloren, Lopez, Romeo Dacayanan, Marcela Bautista, and Francisco Dulay.

Charged Offense and Allegations (as pleaded)

Jaravata was accused of violating Section 3(b) of R.A. No. 3019, as amended.
The information alleged the offense occurred "on or about the period from April 30, 1979 to May 25, 1979, in the Municipality of Tubao, Province of La Union."
The allegation charged that, "being then the Assistant Principal ... and with the use of his influence as such public official, and taking advantage of his moral and official ascendancy over his classroom teachers, with deliberate intent did then and there wilfully, unlawfully and feloniously made demand and actually received payments from other classroom teachers, ROMEO DACAYANAN, DOMINGO LOPEZ, MARCELA BAUTISTA, and FRANCISCO DULAY various sums of money, namely: P118.00, P100.00, P50.00 and P70.00 out of their salary differentials, in consideration of accused having officially intervened in the release of the salary differentials of the six classroom teachers, to the prejudice and damage of the said classroom teachers, in the total amount of THREE HUNDRED THIRTY EIGHT (P338.00) PESOS, Philippine Currency."

Trial Record — Factual Findings by the Sandiganbayan (as stated in its decision)

The Sandiganbayan found no dispute on several baseline facts:
- Ramos, Lloren, Lopez, Dacayanan, Dulay, and Bautista were classroom teachers at Leones Barangay High School.
- Jaravata was the assistant principal and Baltazar was the administrator.
- On January 5, 1979, Jaravata informed the classroom teachers of the approval of the release of their 1978 salary differentials.
- To facilitate payment, Jaravata and the classroom teachers agreed that Jaravata would follow up the papers in Manila and the teachers would reimburse him for his expenses.
The Sandiganbayan found that Jaravata incurred expenses totaling P220.00 and divided that amount by six teachers, resulting in P36.00 per teacher as the agreed reimbursement.
The Sandiganbayan found that, except for Lloren and Ramos, the classroom teachers gave the accused varying amounts after receiving their salary differentials.
Administrator Baltazar did not approve those payments and ordered Jaravata to return the money received from Lopez, Dacayanan, Dulay, and Bautista; Jaravata complied and returned the money.
The Sandiganbayan concluded that Jaravata received amounts in excess of the P36.00 agreed reimbursement from four teachers:
- Lopez: P100.00 (excess P64.00) — cited testimony: TSN,
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