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JOSE REYES Y VACIO v. PEOPLE

FACTS:

The petitioner, Belen Lopez, filed a complaint for cancellation of sale, reconveyance, and damages regarding two parcels of agricultural land owned by her. Her son, Carlos de Guia, forged a deed of sale, falsely claiming ownership of the land. The land was subsequently sold to Ricardo San Juan and mortgaged to Simeon Yangco. Belen's initial complaint was dismissed, but she appealed to the Intermediate Appellate Court (IAC). Her appeal was initially dismissed due to non-payment of docket fees, but Belen successfully reinstated her appeal and the IAC declared the sale and subsequent transfers null and void. Belen filed a motion for execution, which led to Ricardo and the tenants being held in contempt and ordered to reconvey the land. Ricardo and the tenants appealed this decision to the Court of Appeals.

Meanwhile, a separate case was filed by Belen against the tenants in the Department of Agrarian Reform Adjudication Board (DARAB) for ejectment and collection of rents. The Provincial Adjudicator dismissed Belen's complaint and affirmed the transfer certificates of titles of the tenants. Belen appealed this decision to the DARAB, but her motion to set aside the writ of execution was denied. The DARAB Central Office affirmed the Provincial Adjudicator's ruling. Belen appealed to the CA, which reversed the DARAB Central Office's decision and ordered the tenants to vacate the land, deliver its possession to Belen, and pay her the rents. The tenants appealed to the Supreme Court, which affirmed the CA's decision.

Subsequently, the Provincial Adjudicator, Jose V. Reyes, was charged by the Office of the Ombudsman for violation of Section 3(e) of RA 3019 and usurpation of judicial functions under Article 241 of the Revised Penal Code. The charges were based on Reyes' decision in the DARAB case, claiming that he willfully disregarded the final and executory decision of the Court of Appeals declaring Belen as the true owner of the land.

ISSUES:

  1. a) Whether the petitioner was guilty of violating Section 3 (e) of RA 3019 in rendering his decision in DARAB CASE NO. 034 BUL'88; and

  2. b) Whether the petitioner was guilty of usurpation of judicial functions under Article 241 of the Revised Penal Code.

  3. Whether the petitioner exhibited manifest partiality and evident bad faith in rendering his decision in DARAB Case No. 034-BUL'88.

  4. Whether the act of the petitioner caused undue injury to any party, including the Government, or gave any private party unwarranted benefit, advantage or preference in the discharge of his functions.

  5. Whether the petitioner, as Provincial Adjudicator, can be held liable for usurpation of judicial functions.

  6. Whether the mitigating circumstance of old age should be appreciated in favor of the petitioner.

RULING:

  1. The petitioner was correctly held guilty of and liable for violating Section 3 (e) of RA 3019 in rendering his decision in DARAB Case No. 034 BUL'88, but his conviction for usurpation of judicial functions under Article 241 of the Revised Penal Code is reversed and set aside.

  2. The Sandiganbayan correctly convicted the petitioner for violating Section 3(e) of RA 3019. The court held that the petitioner exhibited manifest partiality and evident bad faith in rendering his decision in DARAB Case No. 034-BUL'88. Additionally, the act of the petitioner caused undue injury to the complainant and gave unwarranted benefit, advantage, or preference to the tenants.

  3. The petitioner, as Provincial Adjudicator, cannot be held liable for usurpation of judicial functions. The Court held that the function performed by the petitioner in adjudicating the claims of opposing parties was quasi-judicial in nature and closely akin to the function of a judge of a court of law. Therefore, he cannot be held liable under Article 241 of the Revised Penal Code for usurpation of judicial functions.

  4. The mitigating circumstance of old age should not be appreciated in favor of the petitioner. The Court held that the mitigating circumstance of old age under Article 13(2) of the Revised Penal Code applies only when the offender is over 70 years old at the time of the commission of the offense. Since the petitioner was only 63 years old when he committed the offenses charged, he is not entitled to such mitigating circumstance.

PRINCIPLES:

  • The essential elements of the offense under Section 3 (e) of RA 3019 are: (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) his action caused any undue injury to any party, including the Government, or gave any private party unwarranted benefits, advantage, or preference in the discharge of his functions.

  • Manifest partiality exists when the accused has a clear, notorious, or plain inclination or predilection to favor one side or one person rather than another.

  • Evident bad faith connotes a manifest deliberate intent on the part of the accused to do wrong or to cause damage. It contemplates a breach of sworn duty through some perverse motive or ill will.

  • Gross inexcusable negligence refers to negligence characterized by want of even the slightest care, acting or omitting to act in a situation where there is a duty to act, not inadvertently but willfully and intentionally, with conscious indifference to consequences insofar as other persons may be affected.

  • The crime of usurpation of judicial functions, under Article 241 of the Revised Penal Code, requires that the accused is not a judge or performing a judicial function, but assumed to act as one without being lawfully entitled to do so.

  • Gross inexcusable negligence refers to negligence characterized by the want of even the slightest care, acting or omitting to act in a situation where there is duty to act, not inadvertently but willfully and intentionally, with conscious indifference to consequences insofar as other persons may be affected.

  • Once a judgment becomes final, it is immutable and can no longer be modified in any respect, whether the modification is to correct erroneous conclusions of fact or law, whether made by the court that rendered it or by the highest court of the land.

  • Usurpation of judicial function occurs when an accused, who is not a judge, attempts to perform an act for which the authority is vested only in a judge.

  • The function of a Provincial Adjudicator in adjudicating the claims of opposing parties is quasi-judicial in nature and closely akin to the function of a judge of a court of law.

  • Usurpation of judicial functions under Article 241 of the Revised Penal Code requires the acts constitutive of usurpation of judicial function.

  • The mitigating circumstance of old age under Article 13(2) of the Revised Penal Code applies only when the offender is over 70 years old at the time of the commission of the offense.