FACTS:

Juan Coronado, a newly hired Process Server in the Office of the Clerk of Court of the Regional Trial Court of Antipolo, Rizal, was charged with violation of Section 3(f) of Republic Act No. 3019, otherwise known as the Anti-Graft and Corrupt Practices Act. The charge stemmed from his alleged willful and unlawful neglect and refusal to serve a court order within a reasonable time, which was done for the purpose of giving undue advantage to the plaintiffs and discrimination against the defendants in a civil case. The Sandiganbayan convicted Coronado and imposed on him the indeterminate penalty of imprisonment for six (6) years and one (1) month to nine (9) years and one (1) day. Coronado filed a petition for review on certiorari before the Supreme Court, arguing that his failure to serve the court order was without sufficient justification and did not fall under the elements of the offense under Section 3(f) of Republic Act No. 3019. The Supreme Court reversed the judgment of the Sandiganbayan and acquitted Coronado on reasonable doubt.

ISSUES:

1. Whether or not the failure of the petitioner to successfully serve the 11 July 1984 Order warrants his conviction under Section 3(f) of the Anti-Graft and Corrupt Practices Act.

RULING:

1. The Supreme Court reversed the judgment of the Sandiganbayan and acquitted the petitioner on reasonable doubt. The Court held that the evidence presented did not prove beyond reasonable doubt that the petitioner’s failure to act was motivated by any gain or benefit for himself or knowingly for the purpose of favoring an interested party or discriminating against another. The Court emphasized that the element of obtaining pecuniary or material benefit or advantage in favor of an interested party or discrimination against another is indispensable for a conviction under Section 3(f) of the Anti-Graft and Corrupt Practices Act. The Court also stressed that guilt must be proved beyond reasonable doubt, and the burden of that proof rests upon the prosecution.

PRINCIPLES:

• To convict a person of a crime, his guilt must be proved beyond reasonable doubt, and the burden of that proof rests upon the prosecution.

• The offense of neglecting or refusing to act under Section 3(f) of the Anti-Graft and Corrupt Practices Act requires the additional element of obtaining pecuniary or material benefit or advantage in favor of an interested party or discrimination against another.

• Neglect refers to the failure to do what can be done and what is required to be done.