GR 123045; (November, 1999) (Digest)
G.R. No. 123045 November 16, 1999
DEMETRIO R. TECSON, petitioner, vs. SANDIGANBAYAN AND PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Demetrio Tecson, then Municipal Mayor of Prosperidad, Agusan del Sur, was convicted by the Sandiganbayan for violating Section 3(c) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act). The Information alleged that on or about September 23, 1989, Tecson requested and received P4,000.00 from private complainant Salvacion Luzana for the issuance of a mayor’s permit for her investment business. The prosecution established that Tecson and Luzana agreed to engage in a joint business venture. On September 27, 1989, Tecson obtained ticket booklets from Luzana, sold tickets, and later presented a mayor’s permit in her business’s name. He then demanded a P4,000.00 cash advance, which Luzana reluctantly gave, under the condition that he would not release the permit otherwise. Subsequently, the local Sangguniang Bayan, presided over by Tecson, revoked the business permit via a resolution.
ISSUE
The primary issues were: (1) whether the administrative exoneration by the Sangguniang Panlalawigan barred the criminal prosecution under the doctrines of res judicata and double jeopardy; and (2) whether the Sandiganbayan erred in convicting Tecson despite an NBI expert’s testimony questioning the authenticity of signatures on certain documents.
RULING
The Supreme Court denied the petition and affirmed the Sandiganbayan’s decision. On the first issue, the Court ruled that the administrative dismissal did not constitute a bar to the criminal prosecution. The principle of double jeopardy does not apply because the administrative case and the criminal case are distinct proceedings with different purposes and consequences. An administrative case addresses official misconduct and may result in disciplinary action, while a criminal prosecution seeks to penalize a violation of law with imprisonment or fine. The Court cited Paredes, Jr. v. Sandiganbayan, which held that an administrative exoneration does not extinguish criminal liability, as the two proceedings are separate and independent. Therefore, the Sandiganbayan validly exercised its jurisdiction.
On the second issue, the Court found no grave abuse of discretion in the Sandiganbayan’s evaluation of evidence. The NBI expert’s testimony, which pointed to a single dissimilarity in handwriting (a pen stop in the letter “s”), was deemed insufficient to discredit the entirety of the prosecution’s evidence. The Court emphasized that the falsus in uno, falsus in omnibus maxim is merely permissive and not mandatory. The Sandiganbayan, as the trier of facts, correctly weighed all evidence and found the elements of the offense proven beyond reasonable doubt. The elements for a violation of Section 3(c) of R.A. No. 3019 —that the accused is a public officer who requested or received any gift for himself in connection with any contract or transaction under his official supervision—were satisfactorily established by Tecson’s act of demanding money in exchange for the permit’s issuance. Thus, the conviction stands.