Macaga-an v. People
REITERATIONFacts
The Antecedents: The petitioners, comprising municipal treasurers and provincial auditors from Lanao del Norte and Lanao del Sur, were convicted in 33 cases of estafa through falsification of public and commercial documents. The charges stemmed from the alleged misappropriation of over P2.7 million in government treasury warrants. These offenses fall under Article 315 in relation to Article 171 of the Revised Penal Code. Procedural History: Following their conviction by the Sandiganbayan on July 15, 1981, the petitioners moved on March 14, 1986, to have their cases closed and bonds released, citing an amnesty granted by former President F. E. Marcos on January 28, 1986. The Sandiganbayan denied this motion, requiring proof of the amnesty, which the petitioners could not produce. A subsequent motion for reconsideration, seeking to present secondary evidence of the amnesty, was also denied by the Sandiganbayan in a resolution dated January 27, 1987. The Petition: The petitioners seek a review of the Sandiganbayan's resolution through a petition for certiorari. They argue that the Sandiganbayan erred in ruling that Presidential Decree No. 1082, the amnesty statute they claim applies, does not cover their offenses. Furthermore, they contend that the Sandiganbayan wrongly disallowed the presentation of secondary evidence to prove the alleged amnesty granted by former President Marcos, which they claim was lost during the February 1986 revolution.
Issue(s)
Whether Presidential Decree No. 1082, as amended, applies to the petitioners' convictions for estafa through falsification. Whether the petitioners are disqualified from amnesty under Presidential Decree No. 1182. Whether the petitioners are entitled to present secondary evidence of the alleged amnesty granted by former President Marcos. Whether acts of the President granting amnesty in conflict with existing decrees can be given legal effect.
Ruling
The petition is denied, and the resolution of the Sandiganbayan dated January 27, 1987, is affirmed. The Court held that the petitioners are not entitled to amnesty under the applicable decrees and that their claim of amnesty, even if proven by secondary evidence, would not absolve them of their convictions.
Ratio Decidendi
On the applicability of Presidential Decree No. 1082: While petitioners claimed their applications were under P.D. No. 1082, the Court noted that P.D. No. 1182 may have repealed it. Even assuming P.D. No. 1082 subsisted, its amnesty was for acts committed in furtherance of resistance to duly constituted authorities by members and supporters of the Moro National Liberation Front (MNLF) and the Bangsa Moro Army, or other "anti-government groups with similar motivations and aims." The offenses covered were primarily those related to rebellion, insurrection, sedition, and other crimes against public order. The records did not indicate that the petitioners' convictions for estafa through falsification were committed in furtherance of such resistance; instead, they were characterized as ordinary crimes without political complexion, consisting of diversion of public funds for private gain. On the applicability of Presidential Decree No. 1182: The Court affirmed the Sandiganbayan's ruling that Presidential Decree No. 1182, as amended, did not apply to the petitioners. The decree specifically covers violations of subversion laws or crimes against public order. The petitioners were convicted of estafa through falsification of public and commercial documents, which fall under "Crimes against Property" and "Crimes Against Public Interest" in the Revised Penal Code, not crimes against public order. Furthermore, the applications for amnesty were filed in 1984, long after the prescriptive period under P.D. No. 1182, which required applications by September 30, 1978, or within six months of arrest or surrender. On the admissibility of secondary evidence: The Sandiganbayan declined to allow secondary evidence because, even if the amnesty papers were proven, the petitioners would not be entitled to discharge from their convictions under the applicable amnesty laws. The Court agreed that presenting secondary evidence would be futile if the underlying claim for amnesty was legally untenable. On acts of the President in conflict with decrees: The Court held that supposed acts of the former President granting amnesty in 1985, which were in clear conflict with the restrictions embodied in Presidential Decrees Nos. 1082 and 1182 promulgated by the same President, could not be given legal effect. The President did not amend his own decrees to remove these restrictions, and thus, he must be held to the terms and conditions he had promulgated. If the President acted in contravention of these decrees, the appropriate recourse for the petitioners would be to the Executive Department, not the courts.
Main Doctrine
Amnesty under Presidential Decree No. 1182 is not available to individuals convicted of estafa through falsification of public documents, as such offenses do not fall under "crimes against public order" or "violations of subversion laws," and the applications for amnesty were filed beyond the prescribed period. Furthermore, acts of the President granting amnesty in clear conflict with the restrictions embodied in the very decrees promulgated by him cannot be given legal effect.