People v. Sandiganbayan
REITERATIONFacts
The Antecedents: The Tanodbayan Special Prosecutor filed an information with the Sandiganbayan charging Roberto S. Benedicto, Jose A. Unson, Jaime C. Dacanay, John Doe, Peter Doe, and William Doe with violation of Section 3 (e) of Republic Act No. 3019, as amended. The charge stemmed from the alleged wilful and unlawful causing of undue injury to the Bureau of Customs and/or the government and the public through evident bad faith by importing raw sugar without prior authority, failing to pay customs duty and sales tax, and dumping the imported sugar into the domestic market, causing local sugar prices to drop and forcing local traders to restore sugar trading control to NASUTRA, thereby enabling the accused NASUTRA officers to profit. Procedural History: Accused Roberto S. Benedicto posted bail. He then filed a motion to quash the information on two grounds: (a) immunity from prosecution by virtue of a compromise agreement with the Presidential Commission on Good Government (PCGG), which was approved by the Sandiganbayan and affirmed by the Supreme Court; and (b) the information does not charge an offense punishable under Section 3 (e) of R.A. No. 3019. The Sandiganbayan, in a resolution promulgated on March 7, 1994, dismissed the information against Benedicto. The Special Prosecutor's motion for reconsideration was denied by the Sandiganbayan on July 10, 1996. The Petition: The People of the Philippines, through the prosecution, instituted a special civil action for certiorari to set aside the resolutions of the Sandiganbayan, alleging that they were issued in excess of jurisdiction or with grave abuse of discretion.
Issue(s)
Whether Roberto S. Benedicto is immune from criminal and civil prosecutions for acts or omissions committed prior to February 25, 1986, under the compromise agreement. Whether the information filed with the Sandiganbayan against Roberto S. Benedicto charges the offense punishable under Section 3 (e) of R.A. No. 3019, as amended.
Ruling
The Supreme Court dismissed the petition for certiorari, affirming the resolutions of the Sandiganbayan. The Court found that the information did not charge an offense punishable under Section 3 (e) of R.A. No. 3019, as amended, because it lacked the essential element of undue injury to the government.
Ratio Decidendi
No pertinent ratio decidendi could be extracted from the text provided for the issue of whether Roberto S. Benedicto is immune from criminal and civil prosecutions for acts or omissions committed prior to February 25, 1986, under the compromise agreement. On the issue of whether the information charges an offense punishable under Section 3 (e) of R.A. No. 3019: The Supreme Court agreed with the Sandiganbayan that the information did not sufficiently charge the offense under Section 3 (e) of R.A. No. 3019. The Court took judicial notice that the National Sugar Trading Corporation (NASUTRA) was a government agency authorized to import raw sugar free from taxes and duties. Consequently, the non-payment of customs duty and sales tax, which were not due, could not have caused actual injury to the government. The Court emphasized that undue injury to the government is an essential element of the offense defined under Section 3 (e) of R.A. No. 3019. Without this essential element, the information fails to charge the offense. The Court cited previous rulings in Pecho vs. Sandiganbayan, Fernando vs. Sandiganbayan, Ignacio R. Bunye vs. Sandiganbayan, and Venus vs. Desierto to support its conclusion that the absence of actual damage or undue injury to the government is fatal to a charge under this provision. Therefore, the information, as filed, did not allege facts that would constitute a violation of Section 3 (e) of R.A. No. 3019.
Main Doctrine
The information filed against an accused for violation of Section 3 (e) of R.A. No. 3019 must allege and prove undue injury to the government, which is an essential element of the offense. If the alleged non-payment of taxes is not due, it cannot constitute undue injury.