G.R. No. L-57841 July 30, 1982
BERNARDO GALLEGO and FELIX AGOCILLO, petitioners, vs. SANDIGANBAYAN, respondent.

FACTS

An information was filed in the Sandiganbayan charging petitioners Bernardo Gallego and Felix Agoncillo, along with others, with violation of Section 3(e) of Republic Act No. 3019 , the Anti-Graft and Corrupt Practices Act. The accusation stemmed from their roles as members of examination boards for marine officers. Specifically, Gallego, as a second corrector, allegedly affirmed a rating given to an examinee whose answer in a technical subject was the prayer “Hail Mary.” Agoncillo, as a member of a different board, allegedly gave a high rating to an examinee whose answer was a love letter. The information alleged these acts resulted in the examinees passing, thereby giving them unwarranted benefits through manifest partiality, evident bad faith, or gross inexcusable negligence.
Petitioners filed a motion to quash the information on two primary grounds. First, they argued that Section 3(e) of R.A. 3019 is unconstitutionally vague, particularly the term “unwarranted,” as it fails to give fair notice of what conduct is prohibited, violating due process. Second, they contended the information was defective for charging more than one offense, as it alleged the giving of unwarranted benefits through three alternative modes: manifest partiality, evident bad faith, and gross inexcusable negligence. The Sandiganbayan denied the motion to quash, prompting this petition.

ISSUE

The core issues are: (1) Whether Section 3(e) of R.A. 3019 is void for vagueness; and (2) Whether the information charges more than one offense.

RULING

The Supreme Court dismissed the petition, upholding the validity of the statute and the sufficiency of the information. On the constitutional challenge, the Court held that Section 3(e) does not suffer from vagueness. The term “unwarranted” is sufficiently definite, meaning lacking adequate or official support, unjustified, or without justification. The provision clearly penalizes a public officer’s act of giving unjustified benefits to a private party in the discharge of official functions through the specified modes. The law provides an ascertainable standard of conduct.
Regarding the alleged duplicity of the information, the Court ruled that it charges only one offense. The phrases “manifest partiality,” “evident bad faith,” and “gross inexcusable negligence” merely describe the different alternative modes by which the single offense—giving unwarranted benefits—may be committed. They are not distinct offenses. An information is not defective for alleging various means of committing the same crime. The information in this case validly states the ultimate facts: the parties involved, the time, place, manner of commission, and the designation of the offense, satisfying the constitutional right to be informed of the nature of the accusation.