Professional Documents
Culture Documents
Catacutan vs. People
Catacutan vs. People
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* FIRST DIVISION.
525
526
526 SUPREME COURT REPORTS ANNOTATED
527
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1 Rollo, pp. 48-65; penned by Associate Justice Jose R. Hernandez and
concurred in by Associate Justices Gregory S. Ong and Rodolfo A.
Ponferrada.
2 Id., at pp. 30-36; penned by Judge Floripinas C. Buyser.
3 Now Surigao State College of Technology.
4 Exhibits B and C, Folder of Exhibits No. II, pp. 310-311.
5 Exhibits B-5 and C-5, id.
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6 Exhibit A, id., at p. 309.
7 Exhibits D and G, id., at pp. 312-313.
8 Exhibit H, id., at p. 317.
9 Exhibit J, id., at pp. 318-320.
529
CONTRARY TO LAW.10
During arraignment on September 22, 1998, petitioner
pleaded not guilty.
For his defense, petitioner admitted that he did not
implement the promotional appointments of the private
complainants because of some procedural lapses or
infirmities attending the preparation of the appointment
papers. According to him, the appointment papers were
prepared by SNSAT Administrative Officer, Crispin
Noguera, using blank forms bearing the letterhead of
SNSAT and not of the CHED Regional Office who made the
appointments. He also averred that the appointment
papers cited the entire plantilla11 (1996 Plantilla-OSEC-
DECSB-VOCIS3-19, Pages 1-16) instead of only the
particular page on which the vacant item occurs. He
likewise claimed that he received only the duplicate copies
of the appointments contrary to the usual procedure where
the original appointment papers and other supporting
documents are returned to his office. Finally, he asserted
that the transmittal letter from the CHED did not specify
the date of effectivity of the appointments. These alleged
infirmities, he contended, were formally brought to the
attention of the CHED Regional Director on June 20,
199712 who, however, informed him that the subject
appointments were regular and valid and directed him to
implement the same. Still not satisfied, petitioner sought
the intercession of CHED Chairman Angel C. Alcala in the
settlement of this administrative problem13 but the latter
did not respond. Petitioner alleged that his refusal to
implement the appointments of the private complainants
was not motivated by bad faith but he just wanted to
protect the interest of the government by following strict
compliance in the preparation of appointment papers.
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10 Sandiganbayan Rollo, vol. I, p. 1.
11 Rollo, p. 51.
12 Exhibits 1 and 1-A, Folder of Exhibits No. II, pp. 427-428.
13 Exhibits 2 and 2-A, id., at pp. 429-430.
530
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14 Supra note 2.
15 Rollo, p. 36.
16 Id., at pp. 37-42.
17 Id., at pp. 46-47.
531
Issue
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18 Id., at pp. 48-65.
19 Id., at p. 66.
20 Id., at pp. 78-88.
21 Id., at pp. 402-417.
22 Id., at p. 17.
23 CONSTITUTION, Article III, Section 1. No person shall be deprived of
life, liberty or property without due process of law nor shall any person
be denied the equal protection of the laws.
532
Our Ruling
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24 Philippine Deposit Insurance Corporation v. Commission on Audit,
G.R. No. 171548, February 22, 2008, 546 SCRA 473, 483.
25 People v. Dela Cruz, G.R. No. 173308, June 25, 2008, 555 SCRA
329, 340.
26 Equitable PCI Banking Corporation v. RCBC Capital Corporation,
G.R. No. 182248, December 18, 2008, 574 SCRA 858, 883.
533
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27 Rollo, p. 57.
28 G.R. No. 169534, July 30, 2007, 528 SCRA 577, 587-589.
534
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29 G.R. Nos. 175930-31, February 11, 2008, 544 SCRA 324, 345.
30 People v. Larraaga, 466 Phil. 324, 373-374; 421 SCRA 530, 569
(2004).
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536
3.His action caused any undue injury to any party, including the
government or gave any private party unwarranted benefits,
advantage or preference in the discharge of his functions.31
All the above enumerated elements of the offense
charged have been successfully proven by the prosecution.
First, petitioner could not have committed the acts
imputed against him during the time material to this case
were it not for his being a public officer, that is, as the
Officer-In-Charge (Principal) of SNSAT. As such public
officer, he exercised official duties and functions, which
include the exercise of administrative supervision over the
school such as taking charge of personnel management and
finances, as well as implementing instruction as far as
appointment of teachers.32
Second, petitioner acted with evident bad faith in
refusing to implement the appointments of private
complainants. As the Sandiganbayan aptly remarked:
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31 Ong v. People, G.R. No. 176546, September 25, 2009, 601 SCRA 47, 53-54.
32 TSN, June 17, 2004, p. 5.
537
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33 Rollo, pp. 62-63.
34 Pleyto v. Philippine National Police Criminal Investigation and
Detection Group (PNP-CIDG), G.R. No. 169982, November 23, 2007, 538
SCRA 534, 590.
538