G.R. No. 175991 ; August 31, 2011
JOSE R. CATACUTAN, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Jose R. Catacutan, the Officer-In-Charge of the Surigao del Norte School of Arts and Trades (SNSAT), was charged with violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The charge stemmed from his refusal to implement the promotional appointments of Georgito Posesano and Magdalena Divinagracia as Vocational Instruction Supervisor III, despite the appointments being duly approved and attested as permanent by the Civil Service Commission (CSC) on June 3, 1997, and despite written directives from the Commission on Higher Education (CHED) and the CSC Caraga Regional Office to implement them. Private complainants lodged a complaint with the Office of the Ombudsman for Mindanao. For his defense, Catacutan admitted non-implementation, citing alleged procedural lapses in the appointment papers (e.g., use of SNSAT letterhead instead of CHED, citation of the entire plantilla, receipt of duplicate copies only, and unspecified date of effectivity). He claimed he brought these issues to the CHED Regional Director, who informed him the appointments were regular and valid, and sought the intercession of the CHED Chairman, who did not respond. He asserted his actions were to protect government interest and were not motivated by bad faith. The Regional Trial Court (RTC) convicted him, finding his defiance demonstrated palpable fraudulent purpose and conscious wrongdoing, causing undue injury to the complainants. The Sandiganbayan affirmed the RTC decision in toto.

ISSUE

Whether the petitioner’s constitutional rights to due process and equal protection of the law were violated when he was denied the opportunity to present in evidence the Court of Appeals’ Decision dated April 18, 2001, in CA-G.R. SP No. 51795, which denied the administrative case against him and declared his intention fell short of malice or wrongful intent.

RULING

The petition lacks merit. The petitioner was not deprived of his right to due process. Due process simply demands an opportunity to be heard, which was accorded to the petitioner as he was able to confront and cross-examine witnesses, argue his case vigorously, and explain his defense. There is no denial of due process when a trial court, in the exercise of its discretion, rejects the presentation of evidence it judiciously believes irrelevant and impertinent to the proceeding. The Sandiganbayan correctly noted that the RTC committed no error in refusing to admit the Court of Appeals Decision in the administrative case, as said decision was irrelevant to the criminal proceeding for violation of R.A. No. 3019 . The elements of the crime were sufficiently proven: the accused is a public officer; the act was done in the discharge of official, administrative, or judicial functions; the act was done through manifest partiality, evident bad faith, or gross inexcusable negligence; and the act caused undue injury to any party or gave any private party unwarranted benefits. The petitioner’s continued refusal to implement the promotions despite clear directives from superior authorities constituted evident bad faith. The petition was denied, and the assailed Sandiganbayan Decision was affirmed.