G.R. Nos. L-51065-72. June 30, 1987.
Arturo A. Mejorada, petitioner, vs. The Honorable Sandiganbayan and The People of the Philippines, respondents.

FACTS

Petitioner Arturo A. Mejorada, a right-of-way agent for the Office of the Highway District Engineer in Pasig, was charged with eight counts of violating Section 3(e) of R.A. No. 3019 (Anti-Graft Law). The informations alleged that from October 1977 to February 1978, he conspired with others to facilitate the approval of claims for compensation filed by property owners affected by a road-widening project. He procured their signatures on blank sworn statements and demolition agreements, which were later filled out with inflated property values supported by falsified tax declarations. After the claimants received their checks, Mejorada accompanied them to his car, where they were compelled to surrender most of the money, leaving them with only a fraction (P1,000 each, except one who received P5,000).
The Sandiganbayan found Mejorada guilty on all counts. He filed this petition for certiorari, raising several issues, including the sufficiency of the allegations in the informations, the jurisdiction and composition of the Sandiganbayan, and the legality of the penalties imposed.

ISSUE

The primary issues are: (1) whether the informations sufficiently alleged the elements of violation of Section 3(e) of R.A. No. 3019 ; (2) whether the Sandiganbayan was a duly constituted court; and (3) whether the penalties imposed violated the three-fold rule under the Revised Penal Code.

RULING

The Supreme Court denied the petition, affirming the Sandiganbayan’s decision. On the first issue, the Court held that the informations were sufficient. They clearly alleged that Mejorada, a public officer, with evident bad faith and for personal gain, facilitated the approval of claims, resulting in undue injury to the claimants and the government by appropriating the bulk of the compensation. These allegations squarely constitute the elements of the offense under Section 3(e).
On the second issue, the Court ruled that the Sandiganbayan was validly constituted. Presidential Decree No. 1606 provides that the Sandiganbayan sits in three Divisions of three Justices each. The judgment convicting Mejorada was a unanimous decision of a duly constituted Division (the First Division). A Division functions independently, and its pronouncements are binding as judgments of the Sandiganbayan. The court’s functionality is not impaired by the non-completion of all Divisions, as long as a quorum in a Division is met.
On the third issue, the Court found no error in the imposition of eight separate penalties, totaling 56 years and 8 days. Petitioner erroneously invoked Article 70 of the Revised Penal Code (the three-fold rule), which governs the service of sentences, not their imposition. Courts may impose as many penalties as there are distinct offenses. The limit under Article 70 applies to the actual duration of service, which cannot exceed three times the most severe penalty, up to 40 years. The Sandiganbayan correctly imposed individual penalties for each count.