GR 166467; (September, 2012) (Digest)
G.R. No. 166467; September 17, 2012
DANILO R. QUERIJERO, JOHNNY P. LILANG and IVENE D. REYES, Petitioners, vs. LINA PALMES-LIMITAR, ISAGANI G. PALMES and THE COURT OF APPEALS, Respondents.
FACTS
Petitioners Danilo Querijero, Johnny Lilang, and Ivene Reyes, employees of the Community Environment and Natural Resources Office in Puerto Princesa, were charged with violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act). The Information alleged that on June 3, 1998, they conspired to issue Original Certificates of Title to certain individuals, despite knowing these individuals did not till, occupy, or possess the land, thereby causing undue injury to the heirs of Isidro Palmes. Petitioners filed a Motion to Quash the Information on two grounds: that the facts charged do not constitute an offense, and that the case had been previously dismissed. The Regional Trial Court denied the motion, ruling the Information sufficiently alleged the elements of the offense and that the issues raised were evidentiary matters requiring a full trial.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in affirming the trial court’s denial of the Motion to Quash.
RULING
The Supreme Court dismissed the petition and affirmed the Court of Appeals. On the first ground, the Court held that a motion to quash based on the insufficiency of the facts alleged in the Information tests only the adequacy of the allegations on their face. The Information clearly stated the accused were public officers who, through manifest partiality, evident bad faith, or gross inexcusable negligence, gave unwarranted benefits to private parties, causing undue injury. These allegations sufficiently averred the elements of a violation of Section 3(e) of R.A. No. 3019. Petitioners’ arguments regarding lack of conspiracy and the regularity of their performance of duty were deemed evidentiary matters not proper for resolution in a motion to quash but during trial.
On the second ground, the Court ruled that the prior dismissal of a different administrative complaint (OMB-1-99-1974) filed by another claimant, Douglas Hagedorn, did not constitute a bar to the instant criminal case. While both cases involved the same property and public officials, the complainants and the rights asserted were different. The evidence and factual antecedents in the two cases were not identical. Therefore, the judgment in the earlier case would not automatically apply to the present one. The Court found no grave abuse of discretion in the lower courts’ rulings, as petitioners failed to prove that the trial court acted in a capricious or whimsical manner amounting to lack of jurisdiction.