G.R. No. 237815. October 12, 2022.
ORLANDO A. FUA, JR., PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

The case stemmed from a buy-bust operation and subsequent service of a search warrant against James Largo for violation of the Comprehensive Dangerous Drugs Act in Lazi, Siquijor, on November 25, 2010. Petitioner Orlando A. Fua, Jr., then the Provincial Governor of Siquijor, arrived at the scene during the police operation. He questioned the team leader, Police Inspector Reynaldo Valmoria, about the legality of the operation, demanded to see the search warrant, and inquired into the grounds for its issuance. Based on these actions, an Information was filed charging Fua with obstruction of justice under Section 1(e) of Presidential Decree No. 1829, for allegedly obstructing, impeding, and delaying the service of the search warrant.
During trial, the prosecution presented police witnesses who testified that Fua’s intervention caused a delay and created tension, with one officer stating he felt threatened. The defense presented Fua and other witnesses who asserted that he merely inquired about the warrant as a concerned citizen and friend of Largo, and that he even assisted by signing the inventory of seized items. The Sandiganbayan convicted Fua, ruling that his actions constituted obstruction. He appealed, arguing that the Sandiganbayan lacked jurisdiction and that his acts did not meet the elements of the crime.

ISSUE

The core issue is whether the Sandiganbayan correctly convicted petitioner Orlando A. Fua, Jr. of obstruction of justice under Section 1(e) of P.D. No. 1829.

RULING

The Supreme Court reversed the Sandiganbayan’s decision and acquitted Fua. The Court clarified that for jurisdiction to lie with the Sandiganbayan over an offense punishable under P.D. No. 1829, committed by a public officer, the act must be committed “in relation to his office.” The Court adopted the “nature of the offense” test, requiring an intimate connection between the offense and the official duties. Here, Fua’s act of questioning the police operation was not done in the discharge of his official functions as Governor. His intervention was personal, motivated by his friendship with the suspect and his presence as a private citizen, not by any official duty to supervise police operations, which he had no authority over.
On the merits, the Court found the prosecution failed to prove guilt beyond reasonable doubt. The essential element of “obstructing, impeding, frustrating, or delaying the apprehension of a criminal offender” was not established. The evidence showed the search warrant was successfully served, the inventory was completed with Fua’s signature, and the suspect was apprehended and prosecuted. The police officers’ general claim of feeling “threatened” or of a “delay” was insufficient, as they continued their duties unimpeded. Fua’s act of asking to see the warrant and questioning its basis, without more, is not criminal. It is a permissible act, especially since citizens have a constitutional right against unreasonable searches and seizures. His inquiries did not rise to the level of willful obstruction contemplated by the law.