Monday, July 4, 2016

Case Digest: Catacutan vs. People


G.R. No. 175991; August 31, 2011
JOSE R. CATACUTAN vs. PEOPLE OF THE PHILIPPINES

Facts:
Petitioner Jose Catacutan was held guilty before the Sandiganbayan for the violation of Section 3(e) of RA 3019(Anti-Graft and Corrupt Practices Act) for his refusal to implement the promotion and appointments of Georgito Posesano and Magdalena A. Divinagracia as Vocational Supervisors III despite the directive of CHED and the Civil Service commission. Catacutan questioned the judgment, contending that he was denied due process when he was not allowed to present the CA judgment, dismissing the adiminstrative case against him.

Issue:
Whether or not the judgment, finding petitioner guilty of violating RA 3019, was well founded despite the refusal of the trial court to admit the dismissal of the administrative case as evidence.

Held:
The stubborn defiance by petitioner in carrying out the memorandum issued by CHED was attended by ill motive and bad faith. Such factual finding by the Trial courts, which was affirmed by the sandiganbayan, was based on the evidence presented before it. The non-admittance of the dismissal of the administrative case did not violate petitioner’s right to due process where such dismissal was not relevant to the adjudication of the criminal case. After all, administrative proceedings require a different quantum of proof compared to criminal proceedings, the judgment in one is not dependent on the other.

Present in the case were the elements to find the petitioner guilty of violating Sec3(e) of RA 3019, to wit: 1.that the accused was a public officer performing an official function; 2) that he acted in bad faith; and 3) that injury was caused to another party because of such act.


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