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DEMETRIO R. TECSON v. SANDIGANBAYAN

FACTS:

The petitioner, Demetrio Tecson, was a Municipal Mayor when he was found guilty of violating Section 3[c] of R.A. No. 3019. The private complainant, Salvacion Luzana, claims to be a housewife who occasionally dabbles in farming and was a neighbor of the petitioner. The antecedent facts reveal that Tecson and Luzana agreed to engage in an investment business involving selling tickets for profit. Tecson acted as an agent and received a cash advance from Luzana. Due to the revocation of Luzana's business permit, she filed an administrative case and a civil case against Tecson. Additionally, a complaint for violation of R.A. No. 3019 was filed with the Ombudsman, leading to the present criminal case. The petitioner argues that the decision of the Sangguniang Panlalawigan exonerating him should serve as a bar by prior judgment, and he alleges a violation of his constitutional right against double jeopardy.

ISSUES:

  1. Whether the decision of the Sangguniang Panlalawigan exonerating the petitioner in an administrative case bars the criminal prosecution before the Sandiganbayan.

  2. Whether the dismissal of the amicable settlement in a civil case bars the proceedings before the Sandiganbayan.

  3. Whether the petitioner's trial before the Sandiganbayan violates his constitutional protection against double jeopardy.

  4. Whether the testimony of the prosecution witnesses and the findings of the handwriting expert are sufficient to prove the guilt of the petitioner beyond reasonable doubt.

  5. Whether the Supreme Court can review the factual findings of the Sandiganbayan

  6. Whether the credibility of the prosecution witnesses was properly assessed by the trial court

  7. Whether the testimony of the handwriting expert was sufficient to establish the genuineness of the questioned signatures

RULING:

  1. The decision of the Sangguniang Panlalawigan exonerating the petitioner in an administrative case does not bar the criminal prosecution before the Sandiganbayan. The doctrine of res judicata, which applies to civil cases, has no bearing on criminal proceedings. The administrative liability of a public officer is separate and distinct from their penal and civil liabilities, and the dismissal of an administrative case does not necessarily bar the filing of a criminal prosecution for the same acts.

  2. The dismissal of an amicable settlement in a civil case does not bar the proceedings before the Sandiganbayan. A complaint for misconduct against a public officer cannot be withdrawn at any time to maintain the faith and confidence of the people in the government. Thus, the dismissal of the civil case does not bar the criminal proceedings.

  3. The petitioner's trial before the Sandiganbayan does not violate his constitutional protection against double jeopardy. Double jeopardy only applies in criminal proceedings, and the proceedings before the Sangguniang Panlalawigan were administrative in nature. The elements for double jeopardy to attach were not present.

  4. The testimony of the prosecution witnesses and the findings of the handwriting expert are sufficient to prove the guilt of the petitioner beyond reasonable doubt. The elements of the crime charged are present in the case, and the Sandiganbayan correctly considered both the testimonial and documentary evidence in rendering its judgment of conviction.

  5. The Supreme Court cannot review the factual findings of the Sandiganbayan unless certain exceptions apply, such as when the conclusion is grounded entirely on speculation, when the inference made is manifestly mistaken, when there is grave abuse of discretion, or when the judgment is based on a misapprehension of facts. In this case, the Court found that none of these exceptions were present and that the evidence on record supports the findings and conclusions of the Sandiganbayan.

  6. The credibility of witnesses is generally within the discretion of the trial court, and the Supreme Court will not interfere with the trial court's assessment of credibility unless there is a showing that material facts were overlooked or that there was grave abuse of discretion. In this case, the Sandiganbayan properly assessed the credibility of the prosecution witnesses and gave credence to their positive testimony over the bare denials of the accused. Denial is a weak defense, and the positive assertions of prosecution witnesses deserve more credence and evidentiary weight.

  7. The testimony of the handwriting expert in this case was found to be insufficient to establish the genuineness of the questioned signatures. The expert did not provide specific details on the grounds, data, or details on which he based his conclusion, and his testimony was not of much help in determining the genuineness of the questioned signatures. Therefore, the reliance on the doctrine of falsus in uno, falsus in omnibus (false in one thing, false in everything) is unavailing.

PRINCIPLES:

  • Res judicata is a doctrine of civil law and does not apply to criminal proceedings.

  • A public officer may be held civilly, criminally, and administratively liable for a wrongful act or omission.

  • The administrative liability of a public officer is separate and distinct from their penal and civil liabilities.

  • A complaint for misconduct against a public officer cannot be withdrawn at any time to maintain the faith and confidence of the people in the government.

  • Double jeopardy only applies in criminal proceedings and requires specific elements to be present.

  • The testimony of witnesses and the findings of experts can be considered in proving guilt beyond reasonable doubt.

  • The Supreme Court is not a trier of facts and the factual findings of the Sandiganbayan are conclusive upon the Supreme Court, except in certain exceptions.

  • The trial court's assessment of the credibility of witnesses is entitled to great weight and is even conclusive and binding upon appellate courts.

  • Denial is a weak defense, and positive testimony of prosecution witnesses deserves more credence and evidentiary weight.

  • The opinions of expert witnesses should be based on clear grounds, data, and details, and their testimony should go into the details of their examinations.