Case Summary (A.C. No. 6273)
Facts and Allegations
Between October 1977 and February 1978, Mejorada was alleged to have conspired to inflate claims for government compensation involving the removal and reconstruction of houses and land affected by the Pasig-Sta. Cruz-Calamba Road project in Binangonan, Rizal. The claimants signed blank sworn statements and demolition agreements showing inflated property values, which were falsely supported by forged Declarations of Real Property. After the government issued payments based on these claims, Mejorada distributed only a fraction of the amounts to the claimants, appropriating the remainder for himself and others. The claimants were intimidated and unable to resist until they later filed complaints.
Elements of the Offense Under Section 3(e), RA 3019
Section 3(e) penalizes corrupt practices wherein a public officer causes undue injury to the government or any party, or grants unwarranted benefits to any private party through manifest partiality, evident bad faith, or gross negligence in the course of official functions.
The Court identified three essential elements for violation:
- The accused must be a public officer (which Mejorada was);
- The accused must have caused undue injury to any party or gave unwarranted benefits to a private party in the discharge of official functions;
- The injury or unwarranted benefits must be inflicted through manifest partiality, evident bad faith, or gross negligence.
Court's Analysis on the Elements
The Court determined that the petitioner was indeed a public officer exercising official administrative functions in negotiating compensation claims. The government suffered injury because Mejorda's inflating of claims caused excessive payments beyond just compensation. The private claimants were similarly harmed as they received less than the actual damages entitled to them. Evidence showed Mejorada acted with evident bad faith by falsifying documents and diverting substantial amounts of proceeds. Thus, all elements of Section 3(e) were clearly established.
No Variance Between Charged and Proven Offense
The petitioner argued the evidence showed robbery rather than violation of the Anti-Graft Law. The Court rejected this and held that the entire scheme, including the method of defrauding claimants and government payments, constituted one continuous corrupt practice under Section 3(e). Therefore, there was no variance between the offense charged and the evidence presented.
Jurisdiction of the Sandiganbayan
Mejorada questioned the competence of the Sandiganbayan to try the case, citing incomplete constitution of its divisions. The Supreme Court reiterated its established ruling that each division of the Sandiganbayan, composed of three justices, functions independently and has full juridical authority to decide cases. The First Division was duly constituted and rendered the decision, hence the Sandiganbayan had jurisdiction.
Penalty Imposed and the Applicability of the Three-Fold Rule
The Sandiganbayan imposed an aggregate sentence of fifty-six years and eight days
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Facts of the Case
- Arturo A. Mejorada was employed as a right-of-way agent in the Office of the Highway District Engineer, Pasig, Metro Manila from February 1974 to December 31, 1978. His main duty was to negotiate with property owners affected by highway construction projects for compensation.
- Eight criminal informations were filed by the Provincial Fiscal against Mejorada, alleging violations of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). All eight informations substantially alleged the same set of circumstances, involving claims for compensation related to property affected by the Pasig-Sta. Cruz-Calamba Road, 2nd IBRD Project at Binangonan, Rizal.
- In one example, Mejorada allegedly conspired with unknown persons to facilitate approval of Isagani de Leon's claim for removal and reconstruction costs, after which a check for P7,200 was encashed and only P1,000 was given to the claimant, while P6,200 was appropriated by Mejorada and his confederates, causing damage to both the claimant and the government.
- Mejorada made the claimants sign blank “Sworn Statement on the Correct and Fair Market Value of Real Properties” and “Agreement to Demolish, Remove and Reconstruct improvements,” which inflated the value of properties and improvements far beyond actual values.
- The property declarations used to justify compensation payments were falsified, being registered in names other than those of the claimants.
- After claimants received payments in the Office of the Highway District Engineer, Mejorada divested them of most of the proceeds, leaving only a small fraction as payment, often under threats by himself and an armed companion.
- The claimants later filed complaints supported by sworn statements detailing the fraudulent acts of Mejorada.
Issues Raised on Petition for Certiorari
- Whether the elements of Section 3(e) of RA 3019 — public officer status, undue injury or unwarranted benefit caused, and evident bad faith or partiality in official function — were proven beyond reasonable doubt.
- Whether the Sandiganbayan had jurisdiction and was a competent court to try the case under Presidential Decree No. 1606.
- Whet