CASE DIGEST: People of the Philippines vs. Sandiganbayan

 

PEOPLE OF THE PHILIPPINES, petitioner, vs. SANDIGANBAYAN (FOURTH DIVISION), JESSIE CASTILLO, MELENCIO ARCIAGA and EMERENCIANO ARCIAGA, respondents

G.R. No. 160619. September 9, 2015

FACTS:

Jessie B. Castillo was elected mayor of the Municipality of Bacoor, Cavite. On September 19, 2000, an Information was filed against Castillo charging him with violation of Section 3(e) of RA 3019, in relation to the alleged illegal operation of the Villa Esperanza dumpsite located in Molino, Bacoor, Cavite. According to the Information, Castillo, while in the performance of his official functions as Mayor of Bacoor, gave unwarranted benefits to his co--accused Melencio and Emerenciano Arciaga by allowing the latter to operate the Villa Esperanza dumpsite without the requisite Environmental Compliance Certificate (ECC) and permit from the Environmental Management Bureau.

An administrative complaint for Simple Misconduct had previously been filed against Castillo also in relation to the illegal operation of the dumpsite. The Office of the Ombudsman found Castillo guilty of the administrative charge. On appeal, the Court of Appeals set aside the decision of the Office of the Ombudsman and ordered the dismissal of the administrative complaint against Castillo.

After arraignment and pretrial, Castillo filed with the Sandiganbayan a Motion to Dismiss. He argued that the case against him had been decriminalized by Section 37 of Republic Act No. 9003 and invoked the decision of the Court of Appeals absolving him of administrative liability. His motion was initially denied by the Sandiganbayan in a Resolution dated September 6, 2001.

On September 21, 2001, Castillo filed a Supplemental Motion to Quash the Information on the ground that the same does not charge an offense. He claimed that a public officer may only be held liable for violation of Section 3(e) of RA No. 3019 if he caused undue injury to the government or any private person. Thus, Castillo argued that the undue injury must not only be mentioned in the Information, its extent must also be specified. The Sandiganbayan special division granted Castillo’s Supplemental Motion.

ISSUE:

whether an Information alleging the grant of unwarranted benefits and existence of undue injury must state the precise amount of the alleged benefit unduly granted as well as identify, specify, and prove the alleged injury to the point of moral certainty

RULING:

The main purpose of an Information is to ensure that an accused is formally informed of the facts and the acts constituting the offense charged. Where insufficient, an accused in a criminal case can file a motion to have the Information against him quashed and/or dismissed before he enters his plea.

A motion to quash an Information on the ground that the facts charged do not constitute an offense should be resolved on the basis of the allegations in the Information whose truth and veracity are hypothetically admitted. The question that must be answered is whether such allegations are sufficient to establish the elements of the crime charged without considering matters aliunde. In proceeding to resolve this issue, courts must look into three matters: (1) what must be alleged in a valid Information; (2) what the elements of the crime charged are; and (3) whether these elements are sufficiently stated in the Information. The true test in ascertaining the validity and sufficiency of an Information is “whether the crime is described in intelligible terms with such particularity as to apprise the accused, with reasonable certainty, of the offense charged.”

Castillo is charged with violation of Section 3(e) of RA No. 3019, the elements of which are as follows:

1. The accused must be a public officer discharging administrative, judicial or official functions;

2. He must have acted with manifest partiality, evident bad faith or gross inexcusable negligence; and

3. That his action caused any undue injury to any party, including the government, or giving any private party unwarranted benefits, advantage or preference in the discharge of his functions.

In this case, the Information sufficiently alleges the essential elements of a violation of Section 3(e) of RA No. 3019. The Information specifically alleged that Castillo is the Mayor of Bacoor, Cavite who, in such official capacity, with evident bad faith and manifest partiality, and conspiring with the Arciagas, wilfully, unlawfully and criminally gave unwarranted benefits to the latter, by allowing the illegal operation of the Villa Esperanza dumpsite, to the undue injury of the residents and students in the area who had to endure the ill effects of the dumpsite’s operation.

For as long as the ultimate facts constituting the offense have been alleged, an Information charging a violation of Section 3(e) of RA No. 3019 need not state, to the point of specificity, the exact amount of unwarranted benefit granted nor specify, quantify or prove, to the point of moral certainty, the undue injury caused.

As alleged in the Information, the unwarranted benefit was the privilege granted by Castillo to the Arciagas to operate the dumpsite without the need to comply with the applicable laws, rules, and regulations; the undue injury being residents and students were made to endure the ill effects of the illegal operation. The details required by the Sandiganbayan (such as the specific peso amount actually received by the Arciagas as a consequence of the illegal operation of the subject dumpsite or the specific extent of damage caused to the residents and students) are matters of evidence best raised during the trial; they need not be stated in the Information. For purposes of informing the accused of the crime charged, the allegation on the existence of unwarranted benefits and undue injury under the Information suffices.

Even assuming for the sake of argument that the Information was defective on the ground that the facts charged therein do not constitute an offense, outright quashal of the Information is not the proper course of action.

When a motion to quash is filed challenging the validity and sufficiency of an Information, and the defect may be cured by amendment, courts must deny the motion to quash and order the prosecution to file an amended Information.