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ANTONIO B. SANCHEZ v. PEOPLE

FACTS:

City Engineer Antonio B. Sanchez filed a petition before the Supreme Court assailing the Sandiganbayan's decision finding him guilty of violating Section 3(e) of the Graft and Corrupt Practices Act. The case stemmed from a request made by Barangay Captain Eugenio F. Gabuya Jr. for the improvement of an existing canal in Cogon, Pardo, Cebu City. The Office of the City Engineer approved the request and submitted the necessary documents to the City Council for authorization. However, the ownership of the land where the canal would pass was not verified. The City Council authorized the construction, and the project was implemented by Alvarez Construction. Lucia Nadela, the owner of the land, discovered the construction without her consent and filed a complaint before the Office of the Ombudsman. The Ombudsman filed an Information against Sanchez, who was solely held liable, with the Sandiganbayan. The Sandiganbayan found Sanchez guilty and sentenced him to imprisonment. Sanchez appealed to the Supreme Court, questioning the finding of gross inexcusable negligence and claiming the existence of a prejudicial question in a separate civil case. Respondent countered that Sanchez failed to verify ownership of the land and emphasized the damage and loss suffered by Nadela.

ISSUES:

  1. Whether petitioner acted with gross inexcusable negligence in approving the construction of the canal without determining the ownership of the property.

  2. Whether petitioner can be held liable for the acts of his subordinates.

  3. Whether there is a prejudicial question in Civil Case No. CEB-21748.

RULING:

  1. Yes. The Sandiganbayan found that petitioner acted with gross inexcusable negligence in approving the construction of the canal without first ascertaining the ownership of the property. This negligence deprived the private complainant of the control and use of her land, resulting in loss of income and damage to the property.

  2. No. Petitioner cannot be held liable for the negligent acts of his subordinates, unless there is a finding of conspiracy between them. However, in this case, there is no evidence of conspiracy, therefore petitioner is not liable for the acts of his subordinates.

  3. The argument of petitioner that there is a prejudicial question in Civil Case No. CEB-21748 was already rendered moot and academic because the case was allegedly dismissed by the Regional Trial Court.

PRINCIPLES:

  • Public officers are required to exercise reasonable care in the performance of their duties. Gross inexcusable negligence can result in liability for violation of anti-graft laws.

  • Public officers cannot be held liable for the negligent acts of their subordinates unless there is a finding of conspiracy between them.

  • A prejudicial question exists when the resolution of a question in another case is determinative of the guilt or innocence of the accused in the main case. However, it is not applicable when the issue in the other case has been rendered moot and academic.