GR L 71651; (September, 1987) (Digest)
G.R. No. L-71651 & L-71728 August 27, 1987
PABLITO MENESES and SILVERIO BAUTISTA, appellants, vs. THE PEOPLE OF THE PHILIPPINES, and the HON. SANDIGANBAYAN, respondents. LORENZO MENESES, PABLO SILVA, VIRGILIO CRUZ and CESAR ALMENDRAL, appellants, vs. THE PEOPLE OF THE PHILIPPINES and the HON. SANDIGANBAYAN, respondents.
FACTS
The appellants, consisting of public officers and private individuals, were charged before the Sandiganbayan with violating Section 3(e) of the Anti-Graft and Corrupt Practices Act (R.A. 3019). The information alleged that in March 1977, they conspired to approve and grant Free Patents to Pablito Meneses over portions of land in Los Baños, Laguna, which were owned by the heirs of Ciriaca Arguelles Vda. de Quisumbing and not subject to disposition. The land had been registered under the Quisumbings’ name since 1919, and they had successfully litigated an accion publiciana to recover possession of a portion. Despite this, District Land Officer Braulio Darum issued the patents based on applications supported by inspection certificates and affidavits from the appellants, which contained false claims of ownership and transactions.
ISSUE
The principal issue is whether private individuals can be held liable under Section 3(e) of R.A. 3019, and whether the Sandiganbayan correctly found conspiracy among all appellants.
RULING
The Supreme Court affirmed the Sandiganbayan’s conviction. On the issue of liability for private individuals, the Court ruled that R.A. 3019 expressly applies to both public officers and private persons. Section 4(b) of the law punishes any private individual who knowingly induces a public officer to commit an offense under Section 3. The Court found that the private appellants did not merely apply for patents but actively participated in the fraud by executing false affidavits and documents to facilitate the illegal issuance. Their individual acts collectively demonstrated a conspiracy with the public officers to deprive the Quisumbings of their property and confer unwarranted benefits upon Pablito Meneses. In a conspiracy, the act of one is the act of all. The Sandiganbayan’s factual findings, including the existence of conspiracy, were supported by the evidence and thus upheld. The petitions were dismissed.