G.R. No. 187340 ; August 14, 2013
ANTONIO B. SANCHEZ, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Antonio B. Sanchez, the City Engineer of Cebu City, was charged with violating Section 3(e) of the Anti-Graft and Corrupt Practices Act (R.A. 3019). The case stemmed from a drainage canal project in Barangay Cogon. Upon request from the barangay captain, Sanchez’s office prepared and he approved the program of work and plans for the canal’s construction. The city council authorized the project and appropriated funds, and the mayor entered into a contract with a construction firm. The canal was completed in May 1998.
Subsequently, private complainant Lucia Nadela discovered the canal was constructed on a portion of her titled property without her consent, resulting in the cutting of her nipa trees. She filed a complaint. The Office of the Ombudsman found probable cause only against Sanchez, alleging gross inexcusable negligence for failing to verify land ownership before approving the project, causing undue injury to Nadela. The Sandiganbayan convicted Sanchez, sentencing him to imprisonment and perpetual disqualification from public office.

ISSUE

Whether the Sandiganbayan erred in finding petitioner Antonio B. Sanchez guilty beyond reasonable doubt of violating Section 3(e) of R.A. 3019 through gross inexcusable negligence.

RULING

The Supreme Court denied the petition and affirmed the Sandiganbayan’s decision. The Court held that all elements of the crime under Section 3(e) of R.A. 3019 were present. Sanchez, a public officer, acted with gross inexcusable negligence. As the head of the City Engineering Office, his duties included ensuring the propriety of public works projects. His failure to conduct a basic verification of land ownership—such as a simple title check with the Register of Deeds—before approving the plans and allowing construction on clearly titled private property constituted a blatant disregard of this duty. This negligence was gross and inexcusable, as the duty was primarily lodged in his office.
The Court rejected Sanchez’s defense relying on Arias v. Sandiganbayan, which presumes good faith in approving subordinates’ reports. This presumption was overturned by his gross negligence in omitting a fundamental step. Furthermore, undue injury to Nadela was established: she lost income from her nipa trees, lost use of part of her land, and suffered further damage as informal settlers used the canal as a waste disposal site. The Court also found no merit in the claim of a prejudicial question from a related civil case, noting that the issue of valid expropriation was irrelevant to his criminal liability for negligence. His conviction was thus sustained.