G.R. No. 237864 . July 08, 2020.
EDWIN S. VILLANUEVA AND NIDA V. VILLANUEVA, PETITIONERS, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioners are spouses Edwin S. Villanueva, the Provincial Director of TESDA-Aklan, and Nida V. Villanueva. In 2010, Nida became an incorporator of Rayborn-Agzam Center for Education, Inc. (RACE), a private competency assessment center seeking accreditation from TESDA. Edwin, in his official capacity, signed an Indorsement Letter dated March 31, 2010, supporting RACE’s application for SEC registration. Subsequently, on September 10, 2010, Nida entered into a Contract of Employment with RACE as an In-House Competency Assessor. Later, on November 10, 2010, Edwin approved RACE’s official accreditation as a Competency Assessment Center.
The defense claimed Edwin was unaware of Nida’s incorporator status when he signed the indorsement, arguing his signature was ministerial. Nida asserted her involvement was for a noble purpose and that Edwin did not know of her employment contract. They were charged with violating Section 3(d) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) for having a relative accept employment in a private enterprise with pending business with the public officer.

ISSUE

Whether the Sandiganbayan correctly convicted the petitioners for violation of Section 3(d) of R.A. No. 3019 .

RULING

Yes, the Supreme Court affirmed the conviction. The petition raised questions of law regarding the applicability of Section 3(d) and the sufficiency of evidence, which are reviewable. The Court found all elements of the crime were proven. First, Edwin was a public officer. Second, Nida, his spouse, accepted employment with RACE, a private entity. The Court rejected the argument that RACE was not “private,” as it was a corporation registered with the SEC for profit, not a government instrumentality.
Third, RACE had pending business or application with Edwin’s office when Nida was employed. The “pending business” commenced with the indorsement for SEC registration and continued through the accreditation process, which was approved after Nida’s employment. The law prohibits such employment at any stage while the business is pending, regardless of the officer’s direct involvement in the final approval. Edwin’s approval of the accreditation, after the employment commenced, confirmed the pendency. His lack of knowledge of the employment is immaterial, as the law is meant to prevent conflicts of interest and the appearance of corruption. The Sandiganbayan’s findings were thus upheld.