People v. Nacaytuna
REITERATIONFacts
The Antecedents: Petitioner Santos L. Nacaytuna, then Municipal Mayor of San Miguel, Surigao del Sur, appointed his wife, Marydole V. Nacaytuna, as Municipal Health Officer. Marydole drafted a letter of resignation dated April 7, 2000, which petitioner allegedly received on the same date. In May 2001, Marydole left the conjugal home. In April 2002, Marydole learned that petitioner had accepted her resignation effective at the end of April 2002. Marydole questioned the acceptance before the Civil Service Commission (CSC) and the Office of the Ombudsman, asserting she never tendered the resignation letter. Procedural History: The CSC declared the acceptance of Marydole's resignation illegal and ordered her reinstatement with full backwages. Upon recommendation by the Ombudsman, an information was filed against petitioner for violation of Section 3(e) of R.A. No. 3019. The Sandiganbayan found petitioner guilty beyond reasonable doubt and sentenced him to imprisonment and perpetual disqualification from holding public office. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review, assailing the Sandiganbayan's decision and resolution. He contended that Marydole tendered her resignation on April 7, 2000, which he validly accepted in April 2002; that he is presumed to have regularly performed his duties; that his guilt was not proved beyond reasonable doubt; and that no undue injury was caused as Marydole was reinstated with backwages.
Issue(s)
Whether the prosecution sufficiently proved petitioner's guilt beyond reasonable doubt for violation of Section 3(e) of R.A. No. 3019. Whether Dr. Marydole L. Nacaytuna did not tender her resignation. Whether the guilt of the petitioner was proved beyond reasonable doubt. Whether the Sandiganbayan erred in denying the motion for reconsideration.
Ruling
The petition is DENIED. The Decision of the Sandiganbayan finding petitioner Santos L. Nacaytuna guilty beyond reasonable doubt of violation of Section 3(e) of Republic Act No. 3019, and sentencing him to suffer the indeterminate penalty of imprisonment ranging from six (6) years and one (1) month, as minimum, to ten (10) years, as maximum, with perpetual disqualification to hold public office, and its Resolution denying the motion for reconsideration, are AFFIRMED.
Ratio Decidendi
On the issue of whether the prosecution sufficiently proved petitioner's guilt beyond reasonable doubt for violation of Section 3(e) of R.A. No. 3019: The Court affirmed the Sandiganbayan's finding of guilt. Violation of Section 3(e) of R.A. No. 3019 requires proof that the accused is a public officer discharging administrative or official functions, committed the prohibited act during the performance of his official duty or in relation to his public position, acted with manifest partiality, evident bad faith or gross, inexcusable negligence, and his action caused undue injury to the Government or any private party, or gave any party any unwarranted benefit, advantage or preference. All these elements were established beyond reasonable doubt. The petitioner, as Municipal Mayor, was a public officer, and his acceptance of Marydole's resignation was done in the performance of his official duty. It was proven that Marydole never tendered the resignation letter, thus petitioner acted in evident bad faith by making it appear that it was submitted and by accepting it knowing it was never tendered. These actions caused undue injury to Marydole, resulting in her removal from office and the withholding of her salaries. On the issue of whether Dr. Marydole L. Nacaytuna did not tender her resignation: The Court found that the intention to relinquish and the act of relinquishment were clearly absent. While Marydole admitted to drafting the resignation letter dated April 7, 2000, the evidence showed she did not actually tender it and refrained from pursuing her intention to resign. She continued working even after the letter was drafted and allegedly approved, as she had no intention of resigning. The Court noted that petitioner's account of receiving the resignation letter was inconsistent, initially claiming it did not reach him through normal channels due to their marital relationship, and later testifying it was received by his private secretary. The Sandiganbayan correctly disregarded petitioner's testimony. On the issue of whether the guilt of the petitioner was proved beyond reasonable doubt: The Court reiterated that Marydole consistently maintained she never resigned and continued working even after the alleged acceptance of her resignation, despite her salaries being withheld. She protested the acceptance by writing to the petitioner. The significant delay between the alleged resignation (April 7, 2000) and its acceptance (April 23, 2002) further negated petitioner's claim of good faith. His assertion that he was assessing Marydole's performance before accepting the resignation lacked credence. The Sandiganbayan correctly disregarded his claim of consulting the CSC, noting that such a self-serving claim, unsupported by evidence, betrayed his desire to remove Marydole from office and cause her injury. His failure to inquire directly from Marydole about her intention to resign, coupled with the belated acceptance of an untendered resignation, possibly motivated by marital problems, were clear indications of evident bad faith. On the issue of whether the Sandiganbayan erred in denying the motion for reconsideration: The Court found no error in the denial. The petition for review itself failed to present any reversible error on the part of the Sandiganbayan. The evidence on record supported the conclusion that petitioner acted with evident bad faith and caused undue injury to his wife, thereby violating Section 3(e) of R.A. No. 3019. The penalty imposed by the Sandiganbayan, which included imprisonment and perpetual disqualification from public office, was in accordance with the law and the Indeterminate Sentence Law.
Main Doctrine
A public officer violates Section 3(e) of R.A. No. 3019 when, through evident bad faith, they cause undue injury to a private party by approving a resignation that was never tendered, resulting in the deprivation of office and salaries.