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PEOPLE v. SANDIGANBAYAN

FACTS:

The case involves a petition filed by the People of the Philippines seeking the reversal of the Resolutions issued by the Sandiganbayan. The case is against Jessie B. Castillo, the former mayor of the Municipality of Bacoor, Cavite, who was charged with violation of Section 3(e) of Republic Act No. 3019 in relation to the alleged illegal operation of the Villa Esperanza dumpsite. The Information filed against Castillo alleges that he gave unwarranted benefits to his co-accused by allowing the operation of the dumpsite without the necessary permits. Castillo previously faced an administrative complaint for Simple Misconduct, but it was dismissed by the Court of Appeals. After arraignment and pre-trial, Castillo filed a Motion to Dismiss or Terminate Proceedings, which was initially denied. He later filed a Supplemental Motion to Quash the Information, arguing that it does not charge an offense as it fails to specify the extent of the undue injury caused. The Sandiganbayan Special Division granted Castillo's Supplemental Motion, finding that the Information failed to meet the requirements of the law.

The petitioner filed a motion to quash the information against him on the ground of its insufficiency to charge the crime of violation of Section 3(e) of R.A. No. 3019. The petitioner argued that the information failed to allege with specificity and quantify the unwarranted benefits he allegedly granted to his co-accused, as well as the undue injury caused to the residents and students affected by the dumpsite. The petitioner cited the case of Alejandro vs. People wherein the Supreme Court ruled that undue injury requires proof of actual injury or damage, and that it must be specified, quantified, and proven to the point of moral certainty. The court noted the failure of the information to specify and quantify the alleged unwarranted benefits given to the co-accused. The court also pointed out that the amount allegedly collected from each garbage truck was not mentioned in the information. The court further emphasized that the undue injury must be proven as one of the elements of the crime of violation of Section 3(e) of R.A. No. 3019. The Special Division denied the motion for reconsideration subsequently filed by the People. The issue raised in this case was whether an information charging an accused with violation of Section 3(e) of R.A. No. 3019 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. The court ruled in favor of the petitioner, stating that the information was insufficient to require the petitioner to endure the rigors of a trial.

ISSUES:

  1. Whether the Information filed against Castillo is sufficient and complies with the requirements of Sections 6 and 9 of Rule 110 of the Rules of Court.

  2. Whether the prosecution is required to allege the exact amount of benefits granted by Castillo and the quantify and prove the undue injury caused in the Information.

  3. Whether an Information charging a violation of Section 3(e) of R.A. No. 3019 needs to state, to the point of specificity, the exact amount of unwarranted benefit granted and quantify the undue injury caused.

  4. Whether the Sandiganbayan's application of the Llorente ruling in this case is correct.

  5. Whether outright quashal of the Information is the proper course of action.

    • Whether or not the Sandiganbayan erred in dismissing the Information charging Castillo and the Arciagas with violation of Section 3(e) of R.A. No. 3019
    • Whether or not the dismissal of the case violates the right to speedy disposition of cases

RULING:

  1. The Information filed against Castillo is sufficient and complies with the requirements of Sections 6 and 9 of Rule 110 of the Rules of Court. It sufficiently alleges the essential elements of a violation of Section 3(e) of R.A. No. 3019. It specifically alleged that Castillo, as the Mayor of Bacoor, Cavite, in his official capacity, with evident bad faith and manifest partiality, wilfully, unlawfully, and criminally gave unwarranted benefits to his co-accused by allowing the illegal operation of the dumpsite, causing undue injury to the residents and students in the area.

  2. The prosecution is not required to allege the exact amount of benefits granted by Castillo and to quantify and prove the undue injury caused in the Information. The failure to do so does not render the Information insufficient. The Sandiganbayan erred in quashing the Information based on this ground.

  3. No. An Information charging a violation of Section 3(e) of R.A. No. 3019 need not state, to the point of specificity, the exact amount of unwarranted benefit granted nor specify, quantify, or prove the undue injury caused. The Information need only state the ultimate facts constituting the offense and not the finer details of how and why the crime was committed. The specific details required, such as the specific peso amount or the extent of damage, are matters of evidence best raised during the trial. For the purpose of informing the accused of the crime charged, the allegation on the existence of unwarranted benefits and undue injury under the Information is sufficient.

  4. No. The Sandiganbayan's application of the Llorente ruling in this case is misplaced. While the Llorente ruling held that undue injury must be specified, quantified, and proven to the point of moral certainty, the ruling only applies to the proof of undue injury during the trial, not the filing of the Information. The interpretation by the Sandiganbayan would require the prosecution to include all relevant evidence in the Information and present such evidence even before the accused pleads, which runs counter to the function of a motion to quash as a remedy before trial. Such an interpretation would also undermine the value of the Information as a tool for the accused to understand the charge and be prejudicial to the prosecution.

  5. No. Even if the Information was defective, outright quashal is not the proper course of action. Section 4, Rule 117 of the Rules of Court provides that if the defect may be cured by amendment, the court shall order that an amendment be made. This rule allows the case to proceed without undue delay and is grounded in due process, as the State is entitled to its day in court. Instead of outright quashal, the Sandiganbayan should have ordered the amendment of the Information.

  6. The Supreme Court granted the petition and reversed the Sandiganbayan's Resolutions dated January 9, 2002 and November 3, 2003. The Court ordered the reinstatement of the Information charging Castillo and the Arciagas with violation of Section 3(e) of R.A. No. 3019. The Sandiganbayan was directed to resolve the case with dispatch.

PRINCIPLES:

  • The sufficiency of a complaint or information is determined by whether the crime is described in intelligible terms with such particularity as to apprise the accused, with reasonable certainty, of the offense charged. (Lazarte v. Sandiganbayan)

  • An information is sufficient if it states the name of the accused, the designation of the offense given by the statute, the acts or omissions constituting the offense, the name of the offended party, the approximate date of the commission of the offense, and the place where the offense was committed. (Section 6, Rule 110)

  • The acts or omissions complained of as constituting the offense and the qualifying and aggravating circumstances must be stated in ordinary and concise language, sufficient to enable a person of common understanding to know what offense is being charged and its qualifying and aggravating circumstances, and for the court to pronounce judgment. (Section 9, Rule 110)

  • An Information need only state the ultimate facts constituting the offense and not the finer details of how and why the crime was committed.

  • The proof of undue injury must be established by the prosecution during the trial and not at the time of filing the Information.

  • If an Information is defective, courts should order the prosecution to file an amended Information instead of outright quashal, to avoid prolonging the proceedings and to uphold the State's right to due process.

  • Right to speedy disposition of cases