Case Summary (G.R. No. L-13272)
Case Background
The Office of the Ombudsman charged Benjamin Romualdez with violating Section 3(e) of Republic Act No. 3019, which pertains to the prevention of graft and corrupt practices. The information alleged that during his tenure as the Provincial Governor of Leyte, Romualdez, using his influence with then-President Ferdinand Marcos, was unlawfully appointed as Ambassador to several countries while still holding his gubernatorial position. This dual appointment allegedly allowed him to collect dual compensation from two government sources.
Motion to Quash
Romualdez filed a motion to quash the information on the basis that the facts did not constitute an offense and that any criminal liability had lapsed due to the prescription period. He contended that the statute under which he was charged applied only to particular public officers and that receiving dual compensation did not constitute a violation as he had rendered services in both roles. Additionally, he argued that the time prescribed for legal action had expired since the offense occurred between 1976 and 1986, and the case was only referenced to the Ombudsman in May 2001.
Arguments from the Prosecution
In opposition, the People of the Philippines contended that Romualdez's motion misinterpreted Section 3(e) of RA 3019, which clearly applies to all public officers receiving a salary from the government, and that the right to recover public property from public officials is not barred by prescription due to constitutional provisions that supersede claims of technicality.
Sandiganbayan’s Resolutions
The Sandiganbayan granted Romualdez's motion to quash, asserting that there was insufficient evidence in the Information to show that the actions of Romualdez had caused damage to the government. The court ruled that merely receiving dual compensation does not in itself imply wrongful conduct if actual services were rendered. It further clarified that inefficiency alone does not constitute criminal liability.
Reconsideration and Subsequent Ruling
The People sought reconsideration of the Sandiganbayan's initial ruling, arguing that it contained reversible errors. However, the Sandiganbayan upheld its position in a second resolution, reaffirming that the allegations in the information did not constitute a violation of RA 3019, focusing on the legality of Romualdez's dual appointments and the absence of demonstrable harm to the government.
Jurisdictional Issues
The Supreme Court addressed the procedural concerns regarding the application of Rule 65 for certiorari, which the People used instead of the appeal process under Rule 45. The Court pointed out that while a Rule 65 petition is typically inappropriate when a legal remedy exists through appeal, it can still be warranted when grave abuse of discretion occurs or when significant public interest is at stake.
Ruling on Grave Abuse of Discretion
The Supreme Court held that the Sandiganbayan had acted with grave abuse of discretion by qu
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Case Overview
- The case involves a Petition for Certiorari filed by the People of the Philippines, targeting the Sandiganbayan's Resolutions dated June 22, 2004, and November 23, 2004, regarding Criminal Case No. 26916.
- The Petitioner argues that the Sandiganbayan committed grave abuse of discretion and/or acted with lack or excess of jurisdiction in granting Romualdez's motion to quash the Information.
- The case centers on allegations against Benjamin "Kokoy" Romualdez, the then Provincial Governor of Leyte, for violating the Anti-Graft and Corrupt Practices Act (RA 3019).
Background of the Case
- The Office of the Ombudsman charged Romualdez with violating Section 3 (e) of RA 3019 for allegedly causing undue injury to the government during his tenure from 1976 to February 1986.
- Allegations include:
- Romualdez used his influence with his brother-in-law, President Ferdinand E. Marcos, to obtain dual appointments as Governor and Ambassador to multiple countries.
- This dual role resulted in the collection of a total of P5,806,709.50 in compensation from both the Provincial Government of Leyte and the Department of Foreign Affairs.
Motion to Quash
- Romualdez filed a motion to quash the Information on two primary grounds:
- The facts alleged do not constitute an offense.
- The criminal liability has lapsed due to prescription.
- The defense argued:
- The law applies only to public officers in